SEC Petition Evaluation Report
Petition SEC-00092

Report Rev #: _0 Report Submittal Date: December 3, 2007
Subject Expert(s): James Mahathy
Site Expert(s): NA

ion Under Evaluation

Petition Petition A
ition 3 Type | Receipt Date DOE/AWE Facility Name
SEC-00092 83.14 June 27, 2007 Lawrence Livermore National Laboratory

Proposed Class Definition :

All employees of the Department of Energy (DOE), its predecessor agencies, and DOE contractors or
subcontractors who were monitored, or should have been monitored, for internal exposure to mixed
fission and/or activation product radionuclides while working at the Lawrence Livermore National
Laboratory for a number of work days aggregating at least 250 work days from January 1, 1950
through December 31, 1973, or in combination with work days within the parameters established for
one or more other classes of employees in the SEC.

Related Petition Summary Information
SEC Petition Tracking #(s) | Petition Type DOE/AWE Facility Name Petition Status
NONE NONE NONE NONE

‘Related Evaluation Report Information

Report Title DOE/AWE Facility Name
NONE NONE

ORAU Lead Technical Evaluator: ORAU Review Completed By:

James Mahathy Michael S. Kubiak

Peer Review Completed By: [Signature on file] 12/13/20007
S.E. Glover Date

SEC Petition Evaluation Reviewed By: [Signature on file] 12/13/2007
J. W._Neton Date

SEC Evaluation Approved By: [Signature on file] 12/13/2007

Larry Elliott Date



~ whom NIOSH believes that dose reconst}

SEC-00092

Lawrence Livermore
|

12-03-2007

fabrication, reactor operations, materials|
testing, reactor operations, linear acceler}
product radionuclides resulting from the:
pages 11-13.

National Laboratory (LLNL)

i

research, biological research, nuclear jet research, fuel

ator operations, and chemical separations. Activation/fission

€ operations are documented in ORAUT-TKBS-0035-2,

6.0 Feasibility of Dose Reconstruction for the Proposed Class

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient

information to complete a dose reconstr
without further consideration, to conclud
doses of individual members of the class

In the case of a petition submitted to NIG
determined that a dose reconstruction cai
facility. This determination by NIOSH 4
Per § 83.14(a), the NIOSH-proposed cla:
research, are similarly affected and for

In accordance with § 83.14(a),-NIOSH

research and analysis is required. ‘If so i
separate SEC evaluation rather than delay
Section 10.0). This would allow NIOSH}
consideration of the class that includes a
reconstruction cannot be completed, and
addition of a class of employees to the S

This section of the report summarizes re:
sufficient information to complete the re!
the class of employees for which dose ret
the same statutory and regulatory criteria|
6.1 Feasibility of Estimating In
NIOSH has located thousands of bioassa
ORAUT, 2007b). In addition to the MA.
individual results reported for 617 claima
System. As of July 23, 2007, 88% of cla
however, records for less than 5% of the
Using the MAPPER bioassay data, NIOS
1958 and mixed fission products, starting]
intakes can be used to reconstruct doses ff
workers and all LLNL locations (ORAU

ction, as indicated in this present case, to be sufficient,
e that it is not feasible to estimate the levels of radiation
with sufficient foouracy

SH under 42 C.F.R. § 83.9(b), NIOSH has already

not be completed for an employee at the DOE or AWE
rovides the basis for the petition by the affected claimant.

s defines those employees who, based on completed

hom, as a class,,dose reconstruction is similarly not feasible.

jay establish a Second ‘class of co-workers at the facility for
uction is similarly infeasible, but for whom additional
lentified, NIOSH would:address this second class in a

consideration of the claim currently under evaluation (see
the Board, and; HHS to complete, without delay, their
claimant for whom NIOSH has already determined a dose
ffor which the only possible remedy under EEOICPA is the
EC.

earch findings by which NIOSH determined that it lacked
levant dose recohstruction and on which basis it has defined
onstruction is nlot feasible. NIOSH’s determination relies on
that govern consideration of all SEC petitions.

ternal Exposures

monitoring results for LLNL employees (ORAUT; 2007a;
PER data supplied by LLNL, NIOSH has access to

ints using data stored in the NIOSH OCAS Claims Tracking
ims have external data and 53 % have internal data;

tlaims contain bioassay results for mixed fission products.
1H has developed co-worker intakes for uranium, starting in
in 1974 (ORAUT-OTIB-0065). These derived co-worker
br those radionuclides and time periods for all LLNL
-OTIB-0065-Draft, pages 17-19).

22 of 33 '



SEC-00092

Lawrence Livermore
12-03-2007

© approximately 800 mixed fission pro}
through October 1, 1989; and

NIOSH has found that the MAPPER dati

National Laboratory (LLNL)

Huct results with sample dates ranging from January’ 13, 1974

do not includelany in vivo analysis results. NIOSH has

obtained logbooks for two whole-body cpunter systems used at LLNL (Anderson, 1966; LLNL, 1964-

1966;,LLNL, 1966-1971; Anderson, 1964-1965; LLNL,

1971; LLNL, 1971; LLNL, 1971-1972; I
1974-1975; LLNL, 1975-1976; LLNL, 1
the following:

1967-1969; LLNL, 1969-1970; LLNL, 1970-
LNL, 1972; LUNL, 1972-1973; LLNL, 1973-1974; LLNL,

1976-1979; and LLNL, 1980-1981). Logbook entries indicate

© approximately 50 to 200 in vivo counts were performed each year beginning in 1965;

© logbooks recorded the names of thirt}

multiple counts (additional workers
specifics were provided);

fifteen analyses had results that were|
notations were listed for sixteen cycl
a note:indicates that one worker was

24, 1965;

a person‘with a suspected intake of p|
at least one person involved with sett}

entries made to the logbooks starting}
but made no indication of results;

by 1970, logbooks only recorded the

much of the information in the whold
experimentation information.

Although 325 gross beta results were reported by LLNL
ere not identified as a particular fission product radionuclide

1957 through 1973, these gross results
by LLNL (ORAUT, 2007a). Further,
(disintegrations per minute), dpm/L, cp:
lacks adequate documentation. needed to

|convert counts

-four employees counted in 1965 and 1966, some with
ere counted in 1965 and 1966 but no names or other

noted as “normal spectrum,” with no further specifics;

tron workers in 1965 and 1966, indicating zinc-65 activity;

ised for calibration of zinc-analysis methods on November‘

Jutonium was counted;

ing up the whole-body counter was analyzed as experimental;

in 1967 contained some names along with dates of counting,

Inumber of people counted on a particular date; and

-body counter logbooks dealt with setup, calibration, and

lin the MAPPER data for the period from

unfts of activity used for gross beta results varied from dpm

(counts per minute), epm/L, and Ci, or pCi/L. NIOSH
er minute to intake. In addition, gross beta

measurement results would be at least partially dependent on the radionuclides and material forms to

which an employee was exposed. While}
strontium-90 measurements, the LLNL H
not be precisely interpreted in terms of ir
detected activities of Zinc-65 were given

the efficiencies|of gross beta results were based on ;

azards Control group indicated that gross beta results could
ternal dose or body burden (Miller, 1979). While internally
for sixteen workers, indications are that the implementation

18 of 33



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

11.0 References

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy
Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal
Register/Vol. 67, No. 85/Thursday, p 22296; May 2, 2002; SRDB Ref ID: 19391

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees
Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID:
19392

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special
Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of
2000; Fina! Rule; May 28, 2004; SRDB Ref ID: 22001

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation
Program Act of 2000; as amended; OCAS website

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, Rev. 1; Office of
Compensation Analysis and Support (OCAS); Cincinnati, Ohio; August 2002; SRDB Ref ID: 22401

OCAS-IG-002, Internal Dose Reconstruction Implementation Guideline, Rev. 0; Office of
Compensation Analysis and Support (OCAS); Cincinnati, Ohio; August 2002; SRDB Ref ID: 22402

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray
Procedures, Rev. 03 PC-1; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee;
December 21, 2005; SRDB Ref ID: 20220

ORAUT-OTIB-0065, DRAFT Internal Dosimetry Coworker Data for Lawrence Livermore National
Laboratory, Rev. 00-1A, Oak Ridge Associated Universities; SRDB Ref ID: not currently in the
SRDB—Draft document .

ORAUT-TKBS-00035-2, Lawrence Livermore National Laboratory — Site Description, Rev. 00 PC-1;
Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; October 26, 2005; SRDB Ref
ID: 19553 :

ORAUT-TKBS-00035-4, Lawrence Livermore National Laboratory - Occupational Environmental
Dose, Rev. 00; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; November 18,
2005; SRDB Ref ID: 19557

ORAUT-TKBS-00035-5, DRAFT Lawrence Livermore National Laboratory - Occupational Internal
Dose; Rev. 01C; July 9, 2007; SRDB Ref ID: not currently in the SRDB—Draft document

ORAUT-TKBS-00035-6, Lawrence Livermore National Laboratory — Occupational External Dose,

Rev. 01; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; April 26, 2007; SRDB
Ref ID: 31423

27 of 33



The Board, pursuant to 42 U.S.C. § 7384q, advised the Secretary to designate the
class as an addition to the SEC in a letter received by the Secretary on February 1,
2008.

IV. Designation Findings

Feasibility of Estimating Radiation Doses with Sufficient Accuracy

The Secretary established the feasibility determination for the class of employees
covered by this report based upon the findings summarized below.

(1) Existing data demonstrate that in a wide array of buildings throughout the site,
either fission product radionuclides were used or exposure to them was expected.

(2) Records for less than 5% of the Lawrence Livermore National Laboratory
(LLNL) claims contain bioassay results for mixed fission products. Of the limited
fission product bioassay data for the period prior to 1974 that NIOSH has, NIOSH
finds such data to be insufficient to develop sufficiently accurate coworker fission
product intake models.

(3) While NIOSH has access to some fixed and personal airborne monitoring data
that indicate the presence of fission and activation product radionuclides, the data
are limited and cannot be used to bound or reconstruct internal doses with
sufficient accuracy.

(4) NIOSH has also determined that there are insufficient fission source term data to
adequately reconstruct radiation doses resulting from potential internal exposures
to fission and activation products.

(5) Because NIOSH does not have information to sufficiently quantify the activity
levels for the wide array of fission product radionuclides encountered throughout
the LLNL site, NIOSH finds that it is not feasible to reconstruct with sufficient
accuracy the internal doses from intakes of fission and activation products.

(6) Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient
information to either: (1) estimate the maximum radiation dose, for every type of
cancer for which radiation doses are reconstructed, that could have been incurred
under plausible circumstances by any member of the class; or (2) estimate the
radiation doses of members of the class more precisely than a maximum dose
estimate.

(7) The Board concurred with the NIOSH evaluation and recommended the proposed
class for addition to the SEC.

(8) Although NIOSH found that it is not possible to completely reconstruct radiation
doses for these employees, NIOSH determined that it is possible to reconstruct

HHS Special Exposure Cohort Designation:
Lawrence Livermore National Laboratory



stRvigy
“Es.
on &,

=
5
=
2
3
%y,

*
“tea

CHAIRMAN:

Paul L. Ziemer, Ph.D.
Lafayette, Indiana

MEMBERS:

Josie Beach
Richland, Washington

Bradley P. Clawson
Rexburg, Idaho

Michael H. Gibson
Franklin, Ohio

Mark A. Griffon
Salem, New Hampshire

James E. Lockey, M.D.
Cincinnati, Ohio

James M. Melius, M.D., Ph.D.
Albany, New York

Wanda |. Munn
Richland, Washington

John W. Poston, Sr., Ph.D.
College Station, Texas

Robert W. Presley
Clinton, Tennessee

Genevieve S. Roessler, Ph.D.
Elysian, Minnesota

Phillip Schofield
Bosque Farm, New Mexico

STAFF:

EXECUTIVE SECRETARY:

Lewis V. Wade, Ph.D
Washington, OC

COMMITTEE MANAGEMENT :

Zalda Burgos
Atlanta, Georgia

ADVISORY BOARD ON RADIATION AND WORKER HEALTH
4676 Columbia Parkway, MS: C-46

Cincinnati, Ohio 45226
(513) 533-6825

January 30, 2008

The Honorable Michael O. Leavitt
Secretary of Health and Human Services
Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, DC 20201

Dear Mr. Secretary:

The Advisory Board on Radiation and Worker Health (The Board) has
evaluated SEC Petition-00090 concerning workers at the Mound Plant
near Dayton, Ohio under the statutory requirements established by
EEOICPA and incorporated into 42 CFR Sec. 83.13. The Board
respectfully recommends Special Exposure Cohort (SEC) status be
accorded to all employees of the Department of Energy (DOE), its
predecessor agencies, and DOE contractors or subcontractors who worked
in any areas at the Mound site for a number of work days aggregating at
least 250 work days from October 1, 1949 through February 28, 1959, or
in combination with work days within the parameters established for one
or more other classes of employees in the SEC. The Board notes that
although NIOSH found that they were unable to completely reconstruct
radiation doses for these employees, NIOSH believes that they are able to
reconstruct other components of the internal dose and all external doses.

This recommendation is based on the following factors:

e People working at the Mound facility during this time period worked
on research and production activities related to nuclear weapons
production.

e The NIOSH review of the available monitoring data as well as the
available source term and other information found that they lacked
adequate information necessary to conduct accurate individual dose
reconstructions for internal doses from exposures to Radium 226,
Actinium 227, and Thorium 228 at the Mound facility during the
time period in question.



. Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

LRL, January 3, 1969-December 31, 1969, Hazards Control Radioactivity Sampling Records, Air
monitoring for Site 300; Lawrence Radiation Laboratory (LRL); January 3, 1969 through December
31, 1969; SRDB Ref ID: 35037

Mansfield, May 2006, Correspondence Regarding Copy of LLNL MAPPER Bioassay Results
Database, letter from W. Gary Mansfield, LLNL, to Jennifer L. Hoff; W. Gary Mansfield; May 17,
2006; SRDB Ref ID: 28120

Mansfield, September 2006, Email regarding Questions for Gary Mansfield, electronic mail message
from W. Gary Mansfield, LLNL, to Don E. Bihl, PNNL; Gary Mansfield; September 28, 2006; SRDB
Ref ID: 26886

Miller, 1979, Radiochemical Procedures for Bioassay; Holly H. Miller; May 1, 1979; SRDB Ref ID:
13880

Myers, 1974, Recommended Radiation Protection Guidelines for Proposed Site 300 Experiments,
correspondence from D. S. Myers/T. A. Gibson to J. L. Olsen; D. S. Myers and T. A. Gibson; May 2,
1974; SRDB Ref ID: 35056

Myers, 1988, Activated Air from the Airline Experiment at Site 300, correspondence to Dave Brekkle;
Dave Myers and Mike Trent; March 15, 1988; SRDB Ref ID: 16157

ORAUT, 2007a, Bioassay Data from MAPPER, 34,904 records in Microsoft Excel format; Oak Ridge
Associated Universities; last accessed August 2007; SRDB Ref ID: not currently in the SRDB—
located on the O Drive in the Coworker Data folder

ORAUT, 2007b, Tritium Bioassay Data, 47,473 records in Microsoft Excel format; Oak Ridge
Associated Universities; last accessed August 2007; SRDB Ref ID: not currently in the SRDB—
located on the O Drive in the Coworker Data folder

Soule, 1962, Revision to Bioassay Schedule, memo to Howard G. Parker; Harvey F. Soule; March 22,
1962; SRDB Ref ID: 20908 .

Unknown author, 1961, Internal Ionizing Radiation Exposure Standards, Procedure 202; author not
identified; September 1, 1961; SRDB Ref ID: 15686

Williams, 1975-1977, Urinalysis Results; Gordon Williams; January 23, 1975 through March 30,
1977; SRDB Ref ID: 15483

Williams, 1977, Air Samples Inside Building 850 and 851, correspondence to W. E. Keheley that
includes measurements; G. E. Williams; November 15, 1977; SRDB Ref JD: 16192

33 of 33



Lawrence Livermore

SEC-00092 12-03-2007 National Laboratory (LLNL)
Table of Contents
Evaluation Report Summary: SEC-00092, Lawrence Livermore National Laboratory ...........::: 3

1.0 Purpose and Scope...

2.0 Introduction ........escececseesecseeseesveseencsecsssscsseescseesseeeessecassassessessscsseeseeaeseeerssesessnssessnsasseneeaeeseeseesees 7
3.0 | NIOSH-Proposed Class Definition and Petition Basis............c:sccsssesseesececsesessesseeseesessteseeseenees 8
4.0 Radiological Operations Relevant to the Proposed Class . : 8

4.1 LLNL Operations Description.............0+
4.2 Radiation Exposure Potential from Operations.
4.3. Time Per iod Associated with Radiological Operation:
4.4 Site Locations Associated with Radiological Operations
4.5 Job Descriptions Impacted by Radiological Operations .

5.0 Summary of Available Monitoring Data for the Proposed Class.
5.1 LLNL Internal Monitoring Data... see
5.2 LLNL External Monitoring Data..
5.3. LLNL Workplace Monitoring Dat:
5.4 Radiological Source Term Data ...

6.0 Feasibility of Dose Reconstruction for the Proposed Clas:
6.1 Feasibility of Estimating Internal Exposures
6.2 Feasibility of Estimating External Exposures ............0.c:ceesssessesseseesessessesseeeesseeseseesesees

7.0 Summary of Feasibility Findings for Petition SEC-00092..........sc:sececsecseseeseeseesseseeseessessseseeees 24

8.0 Evaluation of Health Endangerment for Petition SEC-00092........ccssccsssssesseesssesssesseesseesneesseess 24

9.0 NIOSH Proposed Class for Petition SEC-00092

10.0 Evaluation of Second Similar Class ........:ssesssessesseessecssecsessecssessneesseesseesessussssessssseesseeeseseneesness 25

11.0 References ...cecceecscsecsessssessessecsecsesssesseesseessessuessessssssesssessesssesueesssesenesseasecsseessecssessneeseeeseeesese 27

Table 4-1: LLNL Sanctioned Tests ..
Table 4-2: Buildings Involved with Fission and Activation Products .
Table 5-1: Mixed Fission Product Analyses ..

15
19

5 of 33



Lawrence Livermore
SEC-00092 12-03-2007 Nationa] Laboratory (LLNL)

NIOSH has access to only limited fission product bioassay data for the period prior to 1974,
consisting of data available in NOCTS for less than 30 claimants, 325 gross beta results from
MAPPER, and zinc-65 in vivo data for 1965 and 1966 for sixteen cyclotron workers. NIOSH has
been unable to obtain additional in vivo counting results adequate for dose reconstruction for the
period prior to 1974. The in vivo logbooks examined by NIOSH further indicate that LLNL staff
members were routinely modifying the design of the in vivo facility during this timeframe, often
operating it from a testing scheme rather than from a programmatic bioassay scheme. For reasons
stated in Section 5.1 above, NIOSH finds these limited pre-1974 bioassay data insufficient for
development of sufficiently accurate co-worker fission product intake models.

While NIOSH has access to some fixed and personal airborne monitoring data that indicate the
presence of fission and activation product radionuclides, those data cannot be used to bound or
reconstruct doses with sufficient accuracy. Breathing zone results are available for only one building
and for portions of 1960 and 1961 only. Considering the high-activity work that was associated with
laboratory analysis of various nuclear test samples at LLNL, and the unknown characteristics of
biomedical, research, and waste management activities, the general area air sample results available to
NIOSH cannot be used to adequately bound the potential air concentrations that may have existed in
the breathing zones of LLNL staff.

Further, while some of the fission and activation product source term information is known (ORAUT-
TKBS-0035-2, pages 11-13), NIOSH does not have information to sufficiently quantify the activity
levels for the wide array of fission product radionuclides encountered across the LLNL site.

While pre-1974 air monitoring and source term information available to NIOSH are not adequate for
sufficiently accurate dose reconstruction, these data do show that fission product radionuclides were
either used or exposure to them was expected in a wide array of buildings across the site. Therefore,
due to a lack of sufficient bioassay, air monitoring, and source term data, NIOSH finds that it is not
feasible to reconstruct with sufficient accuracy, the internal doses from intakes of fission and
activation products potentially received at LLNL during the period from January 1, 1950 through
December 31, 1973.

Some limited documentation may be available to match radiological workers to specific locations;
however, many of these workers were likely assigned to multiple locations, and as such, the proposed
class cannot be restricted to a specific job title or occupation. Further, NIOSH does not have
workplace monitoring documentation to demonstrate that fission and activation products were not
used or stored in other areas of LLNL involved in radiological activities. NIOSH does not have
information to definitively limit the generation, use, processing, or spread of fission product
radionuclides to specific LLNL locations within the buildings where radioactive material was handled
or stored; thus, the NIOSH proposed class definition includes all known LLNL locations that handled
or stored radioactive material. However, NIOSH has no indication that exposures to mixed fission
products and activation products would have been a concern in administrative areas outside of
radiological areas (e.g., cafeterias, libraries, and office areas outside of radiological areas).

6.2 Feasibility of Estimating External Exposures

23 of 33



Page 5 — The Secretary

Based upon the foregoing, the Director of NIOSH and the Director of CDC recommend that the
Secretary approve and sign the attached designation to add to the SEC certain LLNL employees.

Disapproved Date MAR ~ 3 2099-

Josh Howard, M.D.

7 Attachments:

Tab A — Designation of a Class of Employees from LLNL
Tab B- 42 CFR. pt. 83

Tab C —- LLNL SEC Petition

ao Tab D — NIOSH SEC Petition Evaluation Report, SEC-00092
| Tab E — Board Recommendation Letter to Secretary Leavitt
F- Tab F - Transcripts of relevant Board discussions



SEC-00092

| Lawrence Livermore
12-03-2007

. National Laboratory (LLNL)

with sufficient accuracy, the potential internal doses thatjmay have been received from exposures to

fission and activation products after Dec!
time period associated with this evaluati
January |, 1950 through December 31, 1

mber 31, 1973 (see Sections 5.1 and 6.1). Therefore, the
mn report for miled fission product exposures at LLNL is
p73.

4.4 Site Locations Associated with Radiolopheal Operations

While NIOSH does have access to some
particular areas, NIOSH does not have a
radionuclides were limited to the buildin
the extensive list of site areas involved

nformation that details which radionuclides were handled in
lequate data to determine if exposures to particular +
ps where the radionuclides were known to be handled. Given

ith mixed fission product operations, as presented in Table 4-

2, and NIOSH’s inability to rule out the Use or storage ofimixed fission products and activation

products within other buildings where ra

ioactive material was stored or used, this evaluation report

includes all buildings and work locations|where radioactive materials were handled, processed, tested,
i

or stored.
4.5 Job Descriptions Impacted

NIOSH has limited documentation assoc

by Radiological Operations

| /
ating job titles and/or job assignments with specific

radiological operations or work location’ Without additional: specific information that links known

worker job descriptions with specific wor

k locations,.it is not feasible to narrow listed job.descriptions

to only those workers ‘with potential exposures to radiological operations. Therefore, it is not possible
to determine that any specific workgroup who worked in areas where fission and activation products

were used or stored’ was not potentially e

posed-to the mixed fi fission product exposures defined in this

report, nor is it possible to use job descriptions to define the proposed class. As previously indicated,
NIOSH feels that workers whose job kept them in administrative facilities (e.g. library, cafeteria,

offices) outside of radiological areas should not be included ‘in the class..

5.0 Summary of Available Monitoring Data for the Proposed Class

The primary data used for determining in
such as urinalyses, fecal samples, and wh:
monitoring data from breathing zone and
internal exposure. If personal monitoring
exposures can sometimes be estimated by|
and information characterizing and quanti

This same hierarchy is used for determini
monitoring data from film badges or thern
used to determine such external exposures.
surveys, process knowledge, and source t
potential exposure.

ernal exposures) are derived from personal monitoring data,

le-body counting results. If these are unavailable, the air
keneral area monitoring are used to estimate the potential
and breathing zone area monitoring are unavailable, internal

using more general area monitoring, process information,
fying the source term.

ig the external exposures to the cancer site. Personal
noluminescent dosimeters (TLDs) comprise the primary data
If there are no personal monitoring data, exposure rate

rm modeling can sometimes be used to reconstruct the

{

16 of 33



- Lawrence Livermore
SEC-00092 12-03-2007! National Laboratory (LLNL)

: _, This|page intentionally blank

1

2 of 33



SEC-00092

Lawrence Livermore

iT
i}
| National Laboratory (LLNL)

12-03-2007

report, together with the petition, comme
Board considers appropriate, to make rea
add one or more classes of employees to
advice of the Board, the Director of NIO’
of HHS will make the final decision, taki
Board, and the proposed decision issued
petitioner(s) may seek a review of certain

3.0 NIOSH-Proposed Class

The NIOSH-proposed class includes all

predecessor agencies, and DOE contract
been monitored, for internal exposure to
working at the Lawrence Livermore Nati
least 250 work days from January 1, 195!
days within the parameters established fq

The evaluation responds to Petition SEC:
whose dose reconstruction could not be d
related information: This claimant‘was |
(LLNL) facility during the DOE operati

determination that it is unable to complet
qualified basis for submitting an SEC pe

4.0 Radiological Operation:

The following subsections summarize th
Livermore National Laboratory (main sit}
Site, also known as Site 300, located nea
31, 1973, and the information available t
source materials. Using available source
descriptions, information regarding the i

information describing the processes thrq

occurred and the physical environment ii
within this evaluation report is meant onl

4.1

LLNL was involved in Atomic Energy C
: originally known as the University of Cal

? See 42 C.F.R. pt. 83 for'a full description of the|
available at http://www.cdc.gov/niosh/ocas.

LLNL Operations Description

its of the petitioner(s) and-such other information as the
ommendations to the Secretary of HHS on whether or not to
ithe SEC. Once ‘NIOSH has received and considered the

SH will propose a decision on behalf of HHS. The Secretary
ing into account'the NIOSH evaluation, the advice of the

by NIOSH. As part of this final decision process, the

types of final decisions issued by the Secretary of HHS.

Definition and Petition Basis

mployees of the Department of Energy (DOE), its
rs or subcontractors who were monitored, or should have
ixed fission artd/or activation product radionuclides while
onal Laboratory, for a number of work days aggregating at
through December 31, 1973, or in combination with work
‘one or more other classes of employees in the SEC.
00092, which was submitted by an EEOICPA claimant
lompleted by. NIOSH due to a lack of sufficient dosimetry-
mployed at the Lawrence Livermore National Laboratory
al period as.an|experimental physicist. NIOSH’s
ke a dose reconstruction for an EEOICPA claimant isa
ition pursuant te 42 CFR. § 83.9(b). :

|
s Relevant to the Proposed Class

radiological oferaton conducted at the Lawrence’

e located in Livermore, California and the Explosive Test
Tracy, California) from January 1, 1950 through December
NIOSH to characterize particular processes and radioactive
NIOSH has attempted to gather process and source
entity and quantities of radionuclides of concern, and

ugh which the radiation exposures of concern may have
which they may have occurred.’ The information included

to be a summary of the available information.

pmmission (AEC) work starting in 1950. LLNL was
ifornia Radiation Laboratory at Livermore and later as the

procedures summarized here. Additional internal procedures are

8 of 33



SEC-00092

12-03-2007

Lawrence Livermore
National Laboratory (LLNL)

This

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f

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Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

A more detailed discussion of the information required for dose reconstruction can be found in
OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal
Dose Reconstruction Implementation Guideline. These documents are available at:
http://www.cdc.gov/niosh/ocas/ocasdose.htm!.

NIOSH searched available DOE data to find source term, workplace monitoring, and personnel
monitoring information pertaining to LLNL. NIOSH has obtained internal and external monitoring
data for LLNL workers, documentation that describes the processes and radiological source term
associated with LLNL operations, and information regarding buildings and locations where work was
performed. A sampling of the NIOSH claimant database (using a sampling confidence level of 95%
and confidence interval of 10% for claims received through July 6, 2007) indicates that DOE has
supplied external monitoring data, including occupational medical X-ray data, for 88% of LLNL
claimants and internal monitoring data for 53% of LLNL claimants.

5.1. LLNL Internal Monitoring Data

NIOSH has obtained about 35,000 laboratory-reported bioassay results in electronic format (ORAUT,
2007a; Mansfield, May 2006). These data were supplied by LLNL in the MAPPER (Maintaining and
Preparing Executive Reports) database, a data storage system developed for LLNL by the Sperry
Corporation. The LLNL MAPPER database only contains in vitro monitoring data, primarily from
urinalysis analyzed for uranium, plutonium, gross alpha, gross beta, gross gamma, and mixed fission
products. The following NIOSH summary of the MAPPER data reflects the number of LLNL entries
found in the database, without NIOSH assessment of possible duplicate entries or unusable data
points. NIOSH has found the reported MAPPER data to contain (ORAUT, 2007a; Mansfield, May
2006; Mansfield, September 2006):

© approximately 16,750 uranium urinalysis results dating back to 1958 and continuing through 1996;
© approximately 7,700 results for plutonium-239 analyses from 1957 through 1996;

© 312 results for specific analyses of transuranic radionuclides with sample dates ranging from
February 27, 1964 through May 13, 1996;

¢ about 5,000 gross alpha results with sample dates ranging from March 18, 1956 through August
15, 1996;

© 4,226 gross beta and gross gamma results representing sampling for fission and/or activation
products with sample dates ranging from September 27, 1957 through September 11, 1996 with
325 gross beta results having sample dates prior to 1974 (results denoted as mixed fission product
or MFP are included here as gross beta results because they employed the same radiochemical
analysis);

¢ 19 results reported for specific radionuclides such as cobalt-60 and iodine-131; and

17 of 33



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control end Prevention
lines Compensation Act National Institute for Occupational Safety and Health

- +340 §C.OMB Number. 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form A Page 1 of 2

Use of this form.and disclosure of Soclal Security Number are voluntary. Failure to use this formor disclose
this number will not result-in the denial of any right, benefit, or privilege to which you may be entitled.

Instructions on Completing this Form:

You should use this petition form only if NIOSH has reported to you in writing that it cannot complete the
dose reconstruction needed for your cancer claim.

All other petitioners should use Petition Form 8 to submit a petition to NIOSH.
For Further Information: If you have questions about these instructions, please call the following NIOSH

toll-free phone number and request to speak to someone in the Office of Compensation Analysis and
Support about an SEC petition: 1-800-356-4674.

NIOSH Claim Information — Complete as much information‘as you can in Section A.

Ad NIOSH Tracking Number (indicated on all NIOSH correspondence):

A.2 Print Name of Energy Employee for whom this claim was filed:

First Name Middle Initial » Last Name

A.3 Social Security Number of Energy Employee for whom this claim was filed:

Signature of Person Submitting this Petition — Complete Section B.

Print and sign your name below to indicate that you are petitioning for HHS to consider adding a class
of employees to the Special Exposure Cohort that would include the employee indicated by the
tracking number or name under entry 1 above.

Print your name below: Sign your name below:

First Name — Middle Initial Last Name First Name Middle Initial. Last Name

Please serid this fori to NIOSH at the address below. -

Once NIOSH receives this form, the U.S. Department of Health and Human Services will consider adding a
class of employees to the Special Exposure Cohort. Your contact at NIOSH will be available to inform you of
the progress of your petition.

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Name or Sociat Security Number of First Petitioner: iS _



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, D.C. 20201

MAR - 3 2008

The Honorable John A. Boehner
Minority Leader

United States House of Representatives
Washington, D.C. 20515

Dear Congressman Boehner:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 and 42 C.F.R. § 83.14, the Centers for Disease Control and Prevention’s (CDC) National
Institute for Occupational Safety and Health (NIOSH) initiated a petition for a class of workers
from the Lawrence Livermore National Laboratory to be added to the Special Exposure Cohort
(SEC).

On January 8, 2008, NIOSH presented its findings on the petition evaluation to the
Advisory Board on Radiation and Worker Health (Board). The Board considered the petition,
and on February 1, 2008, I received the Board’s recommendation concerning this petition. I
have also received the deliberations, findings, and recommendations of the Director of NIOSH
and the Director of CDC. I have designated the following class for addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and

DOE contractors or subcontractors who were monitored for radiation exposure
while working at the Lawrence Livermore National Laboratory from January 1,
1950, through December 31, 1973, for a number of work days aggregating at least
250 work days or in combination with work days within the parameters
established for one or more other classes of employees in the Special Exposure
Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



SEC-00092

Lawrence Livermore

12-03-2007 National Laboratory (LLNL)

respect to the underground tests conduct
samples were pulled over the subsequent,
The samples retrieved from NTS were tal
represented the highest radiation dose. J]
were split for duplicate analyses, with hal
Laboratory for analysis (Chew, 2007). |
dirt, had the following exposure rates up

¢ 100 mrad/hour beta at 6 inches

© 10 to 20 mr/hour gamma at | foot
With respect to samples obtained-from th
one (1) rad/hour at the surface of the sam
lived fission products. °

Upon arrival at LLNL, all types of shot
more laboratories depending on the infort
fume hoods.* After analyses were compl
in the basement of Building 155 until the
While shot sample handling was normall
existed for external unshielded electron 4
“loss of containment during sample hand!
with the observed sample dose rates, any|
substantial internal exposure hazards. R:

isotopes of tungsten (W-181/1 85/188) (B

products found in waste materials that w

Depleted uranium and uranium isotopes

Thorium was also used in some lab procd

300. Accelerators and flash x-ray equip:
indoor and outdoor testing. The use of s
which resulted in potential exposures for

Tritium was a major byproduct of reacto:

LLNL. Forms of tritium that existed at J

The potential for exposure to mixed fissi
at LLNL, as indicated by the site monito:
methods (LLNL, 1961-1962). LLNL als

mixed fission products. Potential for fis}

d at NTS, tests were normally conducted on Thursday and
weekend from an average depth of between 750 to 1000 feet.
en from within the core of the weapon blast, which

lhe samples were retrieved within hours after detonation and
llves being sent to LLNL and Los Alamos National

lhe average NTS sample, which consisted of glassy or melted

n receipt at LLNL (Chew, 2007):

le surface craterof test shots, the average dose rate was about
ple. The dose rate initially declined due to decay of short-

amples were dried, assayed, split, and analyzed in one or
mation sought from the test. Analyses were conducted in
ted, the remaining portions of samples were stored in a vault
dose rate-decayed to less ‘than ten mrad/hour (Chew, 2007).-
performed in fume hood environments, the potential
ind photon dose and for internal exposures from. accidental
ng. Given'the high activity levels that would be associated
such releases during sample handling would have constituted
dionuclides detected in the weapons samples included rare
iihl, 2007). NESHAP reports (2000, 2002) reported fission
re attributed to shot samples.

ere used with high explosive materials at Site 300.
sses and in some research and development activities at Site

ent were routinely used at Site 300 in conjunction with both

ich equipment generated air and metal activation products
Site 300 workers.

i
, accelerator, and other operations and research conducted at

ILNL included Hydrides, tritium oxide, and tritium gas.

n and activation products existed from operations performed

ing for mixed fission product exposures using gross activity
maintained administrative limits to control exposures to

ion product exposures existed with accelerator and reactor

operations, handling and analyses of weapon testing shot|samples, biomedical research, research and
development activities, safeguards and security programs, miscellaneous laboratory analyses, and

from waste management research operati
conducted in small groups consisting of

bns. Most research projects performed at LLNL were
nly a few workers and the Hazard Control staff assigned to

14 0f33 |



Lawrence Livermore

SEC-00092 12-03-2007 National Laboratory (LLNL)
Table 4-1: LLNL Sanctioned :Tests
This table spans two pages..."

Year Number of Underground Tests _| Number of Atmospheric Tests
1968 36 7
1969 34 :
1970 38 -
1971 14 -
1972 17 :
1973 14 :
1974 14 :
1975 14 -
1976 12 :
1977, 9 :
1978 12 :
1979 7 :
1980 9 :
1981 8 -
1982 10 :
1983 u :
1984 9 :
1985 10

1986 8 :
1987 9 :
1988 9

1989 10 :
1990 4 -
1991 6 :
1992 4 :

Notes:

- indicates no tests were performed

None of the fissionable tests were conducted within the boundaries of the main LLNL site or Site 300.
However, samples, referred to as “shot” samples, were taken from blast media (soil, water, air) by
LLNL staff and transported to LLNL for physical and chemical analyses. These samples were
handled in several buildings at LLNL including 117, 132, 171, 222, 172, 221, 241, 251 and 419. Shot
sample remnants were secured in Building 155 (Chew, 2007) and were processed by waste
management at Buildings 514 and 612 (Harrach, 2003).

In 1955, LLNL initiated work on nuclear propulsion. For this work, nuclear reactors were built and
tested at LLNL (LLNL, 2006). In 1957, LLNL conducted Project Pluto in an effort to develop a
nuclear ramjet engine to be used in low-flying, supersonic cruise missiles. The project presented a
severe technical challenge (LLNL, no date). Scientists had to devise mass-producible ceramic fuel
elements that could meet stressing operating conditions. From the late 1950s through 1964, LLNL
built and successfully tested six versions of the Tory reactor (fissionable tests were conducted at the
Nevada Test Site). The last version of the Tory reactor generated 600 megawatts (LLNL, 2006).
LLNL also operated a pool-type reactor on the main Livermore site from 1957 through 1980 (LLNL,
2006; DOE, 1992).

LLNL conducted research applying nuclear and isotope sciences to a wide range of problems
including stockpile stewardship, nonproliferation, safeguard technologies, forensic science, and waste

11 of 33



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, D.C. 20201

MAR - 3 2008

The Honorable Harry Reid
Majority Leader

United States Senate
Washington, D.C. 20510

Dear Senator Reid:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 and 42 C.F.R. § 83.14, the Centers for Disease Control and Prevention’s (CDC) National
Institute for Occupational Safety and Health (NIOSH) initiated a petition for a class of workers
from the Lawrence Livermore National Laboratory to be added to the Special Exposure Cohort

(SEC).

On January 8, 2008, NIOSH presented its findings on the petition evaluation to the
Advisory Board on Radiation and Worker Health (Board). The Board considered the petition,
and on February 1, 2008, I received the Board’s recommendation concerning this petition. I
have also received the deliberations, findings, and recommendations of the Director of NIOSH
and the Director of CDC. I have designated the following class for addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors or subcontractors who were monitored for radiation exposure
while working at the Lawrence Livermore National Laboratory from January 1,
1950, through December 31, 1973, for a number of work days aggregating at least

250 work days or in combination with work days within the parameters
established for one or-more other classes of employees in the Special Exposure
Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, D.C. 20201

MAR - 3 2008

The Honorable Richard Cheney
President of the United States Senate
Washington, D.C. ‘20510

Dear Mr. President:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 and 42 C.F.R. § 83.14, the Centers for Disease Control and Prevention’s (CDC) National
Institute for Occupational Safety and Health (NIOSH) initiated a petition for a class of workers
from the Lawrence Livermore National Laboratory to be added to the Special Exposure Cohort

(SEC).

On January 8, 2008, NIOSH presented its findings on the petition evaluation to the
Advisory Board on Radiation and Worker Health (Board). The Board considered the petition,
and on February 1, 2008, I received the Board’s recommendation conceming this petition. I
have also received the deliberations, findings, and recommendations of the Director of NIOSH
and the Director of CDC. I have designated the following class for addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors or subcontractors who were monitored for radiation exposure
while working at the Lawrence Livermore National Laboratory from January 1,
1950, through December 31, 1973, for a number of work days aggregating at least
250 work days or in combination with work days within the parameters

established for one or more other classes of employees in the Special Exposure
Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



Tab D

NIOSH SEC Evaluation Report



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, D.C. 20201

MAR - 3 2008

The Honorable Nancy Pelosi
Speaker of the House of Representatives
Washington, D.C. 20515

Dear Madam Speaker:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 and 42 C.F.R. § 83.14, the Centers for Disease Control and Prevention’s (CDC) National
Institute for Occupational Safety and Health (NIOSH) initiated a petition for a class of workers
from the Lawrence Livermore National Laboratory to be added to the Special Exposure Cohort

(SEC).

On January 8, 2008, NIOSH presented its findings on the petition evaluation to the
Advisory Board on Radiation and Worker Health (Board). The Board considered the petition,
and on February 1, 2008, I received the Board’s recommendation concerning this petition. I
have also received the deliberations, findings, and recommendations of the Director of NIOSH
and the Director of CDC. I have designated the following class for addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors or subcontractors who were monitored for radiation exposure
while working at the Lawrence Livermore National Laboratory from January 1,
1950, through December 31, 1973, for a number of work days aggregating at least
250 work days or in combination with work days within the parameters

established for one or more other classes of employees in the Special Exposure
Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

This page. intentionally left blank

6 of 33



: rs
FT & DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
%

National Institute for

Occupational Safety and Health
Centers for Disease Control

and Prevention (CDC)
200 Independence Avenue, SW
Washington, DC 20201

DATE:
TO: The Secretary
Through: DS
Cos
ES
CDC .
FROM: Director

National Institute for Occupational Safety and Health

SUBJECT: Designating Certain Employees of Lawrence Livermore National Laboratory as
Members of the Special Exposure Cohort under the Energy Employees
Occupational Illness Compensation Program Act of 2000, 42 U.S.C. § 7384q -
ACTION

Action Required: Submit Report to Congress by March 3, 2008
ISSUE

Attached for your approval and signature is a proposed designation to add certain employees
from Lawrence Livermore National Laboratory (LLNL) as members of the Special Exposure
Cohort (SEC) under the Energy Employees Occupational Illness Compensation Program Act
(EEOICPA) (Tab A).

DISCUSSION

EEOICPA established an SEC, a designation applied to certain classes of employees who
worked at U.S. nuclear weapons production facilities of the Department of Energy (DOE) or
Atomic Weapons Employers (AWEs). EEOICPA confers upon SEC designees a presumption of
causation regarding the relation of their cancers to their employment at a DOE or AWE facility.
This presumption allows them to obtain federal compensation under EEOICPA if they incur at
least one of a list of “specified cancers” that, under EEOICPA, are presumptively linked with
occupational exposures to radiation at DOE and AWE facilities. EEOICPA initially included
four classes of employees in the SEC and provided that the President could designate additional
classes as members of the SEC if certain statutory conditions are met. The authority to designate
additional members was delegated by the President to the Secretary of the Department of Health
and Human Services (HHS), who promulgated procedures for doing so (42 C.F.R. pt. 83, Tab
B). Since these procedures were promulgated, Congress has amended EEOICPA to mandate that



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

Harrach, 2003, LLNL NESHAPs 2002 Annual Report, UCRL-ID-113867-03; Robert J. Harrach,
Gretchen M. Gallegos, Sylvie-Ring Peterson, Paula J. Tate, Nicholas A. Bertoldo, Kent R. Wilson,
Paris E. Althouse, and Jennifer M. Larson; June 1, 2003; SRDB Ref ]D: 23051

Howe, 1961, Bioassay Program, PWH-248-61-memo to W. B. Reynolds; P. W. Howe; March 17,
1961; SRDB Ref ID: 20569

LLNL, no date, Fifty Years of Accomplishments, 1952 through 2002; Lawrence Livermore National
Laboratory (LLNL); no date; SRDB Ref ID: 23405

LLNL, 1960-1961, Routine Air Monitoring Data Sheets, November 1960 to August 1961; Lawrence
Livermore National Laboratory (LLNL); November 1960 through August 1961; SRDB Ref ID: 35122

LLNL, 1960-1962, Routine Air Monitoring Data Sheets, 1960 to April 1962; Lawrence Livermore
National Laboratory (LLNL); 1960 through April 1962; SRDB Ref ID: 35076

LLNL, 1960-1970, Soil and Air Samples, Site 300; Lawrence Livermore National Laboratory
(LLNL); 1960 through 1970; SRDB Ref ID: 35058

LLNL, December 12, 1960-August 31, 1961, Lapel Samples, Building 125; Lawrence Livermore
National Laboratory (LLNL); December 12, 1960 through August 31, 1961; SRDB Ref ID: 35120

LLNL, 1961-1962; Routine Air Monitoring Data Sheets, September 1961 to May 1962; Lawrence :
Livermore National Laboratory (LLNL); September 1961 through May 1962; SRDB Ref ID: 35121

LLNL, 1964-1966, Whole-Body Counter Logbook #1, September 18, 1964 to December 14, 1966;
Lawrence Livermore National Laboratory (LLNL); September 18, 1964 through December 14, 1966;
SRDB Ref ID: 35017

LLNL, 1965-1967, Environmental Sample Record, Air Filters (composite) for Site 300; Lawrence
Livermore National Laboratory (LLNL); various dates between 1965 and 1976; SRDB Ref ID: 35049

LLNL, 1966-1971, Whole-Body Counter Logbook #2, December 16, 1966 to August 23, 1971;
Lawrence Livermore National Laboratory (LLNL); December 16, 1966 through August 23, 1971;
SRDB Ref ID: 35018

LLNL, 1967, 88-Jnch Cyclotron Operation, misc. radiation files; Lawrence Livermore National
Laboratory (LLNL); 1967; SRDB Ref ID: 21523

LLNL, 1967-1969, Whole-Body Counter #2 Logbook #1, September 18, 1967 to July 29, 1969;
Lawrence Livermore National Laboratory (LLNL); September 18, 1967 through July 29, 1969; SRDB
Ref ID: 35020

LLNL, March 1, 1967-January 5, 1968, Radioactivity Sampling Record, Building 193 and 281;
Lawrence Livermore National Laboratory (LLNL); March |, 1967 through January 5, 1968; SRDB
Ref ID: 36061

29 of 33



HHS Designation of Additional Members of the

' Special Exposure Cohort
under the
Energy Employees Occupational Illness Compensation Program Act of 2000

Designating a Class of Employees from

Lawrence Livermore National Laboratory
Livermore and Tracy, California

HHS Special Exposure Cohort Designation:
Lawrence Livermore National Laboratory



Tab A

Designation of a Class of Employees to the Special Exposure Cohort



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

The health endangerment determination for the class of employees covered by this evaluation report is
governed by EEOICPA and 42 C.F.R. § 83.14(b) and § 83.13(c)(3). Pursuant to these requirements, if
it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH
must determine that there is a reasonable likelihood that such radiation doses may have endangered
the health of members of the class. The regulations require NIOSH to assume that any duration of
unprotected exposure may have endangered the health of members of a class when it has been
established that the class may have been exposed to radiation during a discrete incident likely to have
involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If
the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is
required to specify that health was endangered for those workers who were employed for a number of
work days aggregating at least 250 work days within the parameters established for the class or in
combination with work days within the parameters established for one or more other classes of
employees in the SEC.

The petitioner did not provide, and NIOSH has not obtained, any information to indicate that members
of the class were exposed to radiation during a discrete incident likely to have involved levels of
exposure similarly high to those occurring during nuclear criticality incidents. However, the evidence
reviewed in this evaluation indicates that some workers in the class may have accumulated chronic
radiation exposures through unmonitored exposure to fission products. LLNL generated or processed
unknown quantities of mixed fission products during the proposed class period as part of work
conducted for DOE. Consequently, NIOSH is specifying that health may have been endangered for
those workers covered by this evaluation who were employed for a number of work days aggregating
at least 250 work days within the parameters established for this class or in combination with work
days within the parameters established for one or more other classes of employees in the SEC. |

9.0 NIOSH Proposed Class for Petition SEC-00092

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses
with sufficient accuracy. This class includes all employees of the Department of Energy (DOE), its
predecessor agencies, and DOE contractors or subcontractors who were monitored, or should have
been monitored, for internal exposure to mixed fission and/or activation product radionuclides while
working at the Lawrence Livermore National Laboratory for a number of work days aggregating at
least 250 work days from January 1, 1950 through December 31, 1973, or in combination with work
days within the parameters established for one or more other classes of employees in the SEC.

10.0 Evaluation of Second Similar Class

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility,
similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not
be feasible, and for whom additional research and analyses is required. Such a class would be
addressed in a separate SEC evaluation rather than delay consideration of the current claim. At this
time, NIOSH has not located information suggesting that there is likely to be a second, similar class of
employees at LLNL for whom dose reconstruction may not be feasible.

25 of 33



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

As LLNL had to deal with radioactive wastes, studies on the handling and treatment of wastes were
performed. Waste processing and optimizing were studied in Building 513. Among the radionuclides
recorded in a LLNL inventory for Building 513 were americium-241, barium-133, carbon-14, cesium-
134, cesium-137, tritium, iodine-125, iodine-131, phosphorus-32, plutonium-238, plutonium-239,
plutonium-240, plutonium-241, plutonium-242, and thorium-232. Consolidation, evaporation, and
waste filtration were studied and implemented at Building 514. A wide range of radionuclides have
been observed from monitoring in Building 514. Liquid radioactive wastes were either treated and or
stored at Buildings 513 and 514, while dry or solid wastes were normally handled at Buildings 612 or
614. Waste materials were received at Building 625 (Harrach, 2003).

LLNL performed extensive chemical and biological research, sampling, and analyses in support of all
other operations. This work included bench-scale synthesis and testing of chemical compounds,
development of bench-scale polymers and composites, as well as collection, analyses, and monitoring
of personnel, process, environmental, and waste samples (DOE, 1992). An example of these
operations is the preparation of aqueous samples containing radioactive tracers for use with stable
isotopic studies (Harrach, 2003). Radioactive materials, some of which were low-level tracers, were
used with these latter operations in Buildings 132, 151, 167, 168, 169, 171, 173, 174, 175, 176, 217,
222, 241, 253, 254, 255, 334, 377, and 378. .

4.2 . Radiation Exposure Potential from Operations

The potential for external radiation dose existed at all locations where radioactive materials were
handled or stored, where materials were tested by explosive or radiographic means, and from
exposures resulting from accelerators, nuclear reactors, and cyclotrons. Based on LLNL operations .
outlined in Section 4.1, sources of potential external exposures included primarily beta and photon
radiations. The beta and photon (X-ray and gamma) energy ranges and geometries varied across
operations. The potential for exposure to neutrons existed in several operations; the energy range has
been considered to be 0.1 —- 2.0 MeV (ORAUT-TKBS-00035-6, page 11).

There were numerous sources of potential internal radiation exposures at LLNL during the proposed
class timeframe of January 1, 1950 through December 31, 1973. During that time, internal exposures
to alpha radiation potentially resulted from releases and subsequent re-suspension of uranium,
plutonium, thorium, and transuranic radionuclides in areas where weapons-related work, fuel
fabrication and clean-up, reactor utilization, and waste disposal occurred. There were also sources of
potential internal exposure to beta and gamma emitters resulting from shot sample analyses, high
explosive testing, biomedical research, safeguards research, laboratory analyses, and waste
management tasks, as well as from the use of particle accelerators at the Livermore and Site 300
campuses.

Processing of the nuclear test shot samples represented a frequent and long-term radiation exposure
hazard at LLNL. LLNL analyzed samples from most of the tests presented in Table 4-1. With respect
to shot samples obtained from above ground (atmospheric) testing, sample filters were sent to LLNL
for analyses (Chew, 2007). The average dose rate upon receipt was about one (1) rad/hour at one foot.
Samples were divided in a ventilated hood within one-half hour after receipt. These samples were
then dissolved during the morning of receipt to further reduce the beta dose rate. Exposure rates to the
skin during the sample splitting and dissolution processes averaged about 100 mrad/hour. With

13 of 33


SEC-00092

Lawrence Livermore

12-03-2007 National Laboratory (LLNL)

LLNL, 1969-1970, Whole-Body Counte!
Lawrence Livermore National Laborato
Ref ID: 35021

LLNL, January 9, 1969-January 11, 197
National Laboratory (LLNL); January 9

LLNL, 1970-1971, Whole-Body Counte
Lawrence Livermore National Laborato:
SRDB Ref ID: 35022

LLNL, 1971, Whole-Body Counter #2 I}
Lawrence Livermore National Laborato:
SRDB Ref ID: 35023

LLNL, 1971-1972, Whole-Body Counte!
Lawrence Livermore National Laborato
Ref ID: 35024

LLNL, January 14, 1971-January 11, 19}
National Laboratory (LLNL); January 1

LLNL, 1972, Whole-Body Counter #2 1
Livermore National Laboratory. (LLNL)
35025

LLNL; 1972-1973, Whole-Body Countel
Lawrence Livermore National Laborato:
SRDB Ref ID: 35026

LLNL, 1973-1974, Whole-Body Countei
Lawrence Livermore National Laborato
SRDB Ref ID: 35027

LLNL, 1974-1975, Whole-Body Countei
Lawrence Livermore National Laborato
SRDB Ref ID: 35028

LLNL, 1975-1976, Whole-Body Counte:

#2 Logbook #2, July. 30, 1969 to September 9, 1970,
ly (LLNL); July|30, 1969 through September 9, 1970;SRDB -

, Air Monitorii
1969 through J:

g, multiple buildings; Lawrence Livermore
anuary 11, 1971; SRDB Ref ID: 36014

#2 Logbook #3, September 10, 1970 to January 19, 1971;
ry (LLNL); September 10, 1970 through January 19, 1971;

ebook #4, January 10, 1971 to September 1, 1971;
(LLNL); January 10, 1971 through September 1, 1971;

#2 Logbook #5, September 2, 1971 to April 6, 1972;
(LLNL); September 2, 1971 through April 6, 1972; SRDB

73, Air:Monitoring, Building 281; Lawrence Livermore
, 1971:through January 11; 1973; SRDB Ref ID: 35131

pgbook #6, ‘April 7, 1972 to October 31, 1972; Lawrence
April 7, 1972 through October 31, 1972; SRDB Ref ID:

#2 Logbook, October 31, 1972 to November 15, 1973;
ly (LLNL); October 31, 1972 through November 15, 1973;

#2 Logbook #8, November 19, 1973 to December 14, 1974;
(LLNL); November 19, 1973 through December 14, 1974;

#2 Logbook #9, December 14, 1974 to December 3, 1975;
(LLNL); Decémber 14, 1974 through December 3, 1975;

#2 Logbook #10, December 9, 1975 to October 5, 1976;

Lawrence Livermore National Laboratory (LLNL); December 9, 1975 through October 5, 1976;

SRDB Ref. 1D: 35029

LLNL, 1976-1979, Whole-Body Countei

#2 Logbook #11, October 6, 1976 to December 12, 1979;

Lawrence Livermore National Laboratory (LLNL); October 6, 1976 through December 12, 1979;

SRDB Ref ID: 35030

30 of 33



SEC-00092

Lawrence Livermore

National Laboratory (LLNL)

characterization and analysis. LLNL pe
defense and energy applications, and for

i
12-03-2007 |

formed caus using linear accelerators for a variety of
activation product production. Accelerators used included a

10-MeV tandem accelerator, a 100-MeV/ linear accelerator (LINAC), and a Cockcroft Walton

accelerator. LLNL also housed a 90-inc!
plutonium, and tritium.

cyclotron used to conduct experiments with uranium,

Accelerator type devices and related services were housed in Buildings 192, 194,210, 212, 241, 298,

327, 341, 421, and 435. At Site 300, LL]

including flash X-ray equipment (DOE,
LLNL from the Nevada Test Site in the

|L operated linear accelerators and radiography devices,
992; LLNL, no date). The XR2 accelerator was moved to
950s. A new linear accelerator, know as the Astron LINAC,

greatly exceeded the capabilities of the {R2 machine. The Astron machine required the invention of

anew kind of electron accelerator that

magnetically confine and heat.a plasma
2006). Operations using flash generatio
801, 851 Firing Table, and open areas.

jould produce an intense circulating electron beam to
matrix. The Astron concept was tested at Site 300 (LLNL,
and accelerators at Site 300 were conducted in Buildings

econdary radionuclides expected from the operation of linear ;

accelerators at LLNL included activation products such as carbon-11, nitrogen-13, oxygen-1'5,

nitrogen-16, argon-41, zinc-65, and zirc

nium-95 (Williams, 1975-1977; Myers, 1988).

LLNL performed extensive work with tritium compounds at the Hydrogen Research Facility

(Building 331) where various projects u:
facility was in the elemental form or in
into elemental form by heating. Althou;
systems during the.removal of tritium fr
tritiated water in the building (DOE 199
compounds or synthesizing lithium hyd
(DOE, 1992).

LLNL performed research and testing o:
demonstrated improved plutonium fabri
research in plutonium metallurgy. This
is some evidence that fission products

LLNL also fabricated metals using both|
contained plutonium). Fabrication operé
Transuranic radionuclide research was q

LLNL performed research in the field o
These activities were conducted in Buil
of the research, carbon-14 and sulfur-35
time. Other research projects used radi
Radiological inventory records show th:
biomedical program: americium-241, ay
cesium-134, cesium-137, neptunium-23}
strontium-85, and several isotopes of pl

ing tritium were conducted. Most of the tritium used at the
he:form of metal hydride compounds.capable of being turned
ch some. tritiated water was formed in the tritium cleanup

m. glovebox atmospheres, there was no programmatic use of
2). A small amount of tritium'was used at LLNL for labeling
ide (DOE, 1992). Tritium triggers were tested at Site 300 -

plutonium-bearing engineering assemblies, developed and
ation techniques, and performed fundamental and applied
ork was conducted in Building 332 (Harrach, 2003). There

ere also used in|Building 332 at some period in the 1960s.

depleted uranium and enriched uranium (some of which
ations included milling, machining, and shaping (DOE, 1992).
londucted in Bulding 251.

genetics and biomedical sciences using radioactive materials.
ings 361, 362, 363, 364, 365, 366, 367, and 412. With some
were injected into animals and the animals were studied over
logical tracers in genetic studies (Harrach, 2003). _

it the following radionuclides were handled within the
ericium-243, carbon-1 4, cadmium-] 09, cobalt-57, cobalt-60,
7, neptunium-239, tritium, phosphorus-32, sulfur-35,

tonium and uranium (Harrach, 2003).



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, D.C, 20201

MAR - 3 2008

The Honorable Mitch McConnell
Minority Leader

United States Senate
Washington, D.C: 20510

Dear Senator McConnell:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 and 42 C.F.R. § 83.14, the Centers for Disease Control and Prevention’s (CDC) National
Institute for Occupational Safety and Health (NIOSH) initiated a petition for a class of workers
from the Lawrence Livermore National Laboratory to be added to the Special Exposure Cohort
(SEC).

On January 8, 2008, NIOSH presented its findings on the petition evaluation to the
Advisory Board on Radiation and Worker Health (Board). The Board considered the petition,
and on February 1, 2008, I received the Board’s recommendation concerning this petition. I
have also received the deliberations, findings, and recommendations of the Director of NIOSH
and the Director of CDC. I have designated the following class for addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and

DOE contractors or subcontractors who were monitored for radiation exposure
while working at the Lawrence Livermore National Laboratory from January 1,
1950, through December 31, 1973, for a number of work days aggregating at least
250 work days or in combination with work days within the parameters
established for one or more other classes of employees in the Special Exposure
Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

Evaluation Report Summary: SEC-00092, Lawrence Livermore
National Laboratory

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH)
addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the
Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C.
§ 7384 et seq. (EEOICPA) and 42 C.F.R. 83, Procedures for Designating Classes of Employees as
Members of the Special Exposure Cohort Under the Energy Employees Occupational Illness
Compensation Program Act of 2000.

NIOSH-Proposed Class Definition

The NIOSH-proposed class includes all employees of the Department of Energy (DOE), its
predecessor agencies, and DOE contractors or subcontractors who were monitored, or should have
been monitored, for internal exposure to mixed fission and/or activation product radionuclides while
working at the Lawrence Livermore National Laboratory for a number of work days aggregating at
least 250 work days from January 1, 1950 through December 31, 1973, or in combination with work
days within the parameters established for one or more other classes of employees in the SEC.

Feasibility of Dose Reconstruction

Per EEOICPA and 42 C.F.R. § 83.14(b), NIOSH has established that it does not have sufficient
information to complete dose reconstructions for individual members of the class with sufficient
accuracy. NIOSH lacks sufficient personal and workplace monitoring data to adequately determine
the potential intake of fission and/or activation product radionuclides, making reconstruction of
internal fission and/or activation product doses infeasible.

Health Endangerment Determination

The NIOSH evaluation did not identify evidence supplied by the petitioners or from other sources that
would establish the class was exposed to radiation during a discrete incident likely to have involved
exceptionally high-level exposures, such as nuclear criticality incidents or other events involving
similarly high levels of exposure. However, the evidence reviewed in this evaluation indicates that
some workers in the class may have accumulated chronic radiation exposures through intakes of
fission and/or activation products. Consequently, in accordance with 42 C.F.R. § 83.13(c)(3)(ii),
NIOSH has determined that health may have been endangered for those workers covered by this
evaluation who were employed for a number of work days aggregating at least 250 work days within
the parameters established for this class, or in combination with work days within the parameters
established for one or more other classes of employees in the SEC.

3 of 33



SEC-00092

Lawrence Livermore

12-03-2007 National Laboratory (LLNL)

NIOSH has identified a LLNL bioassay
bioassay of personnel involved with nuc!
requirement to check for fission product:

NIOSH has also reviewed bioassay data
(LBNL); these cards appeared to be a po}
LBNL data cards noted the ‘word “Liver
January 1960-August 1962; LLNL & LB
products, which accompanied the gross
radionuclides were mentioned. NIOSH
performed analyses of bioassay samples
LBNL workers (Grill, 1965; Soule, 1963
were often reported for LBNL workers.
refer to the gross alpha procedure used aj
gross beta procedure as “Los Alamos.”

procedure pertinent to 1966; the procedure does require

lear samples and other operations, but there was no specific
(Balanda, 1966).
bards obtained from Lawrence Berkeley National Laboratory
ential source of bioassay data for LLNL workers. Some

ore” for many bross alpha results (LLNL & LBNL,

NL, 1960-1968). There were some separate results for fission
Ipha “Livermore” results; in some cases specific ~

xamined the LBNL data to determine if LBNL had,

for. LLNL employees. NIOSH used bioassay rosters of

}) to determine that the data with the notation “Livermore”
Indications are that the word “Livermore” was often used to
LBNL (LLNL| 1967, page 3). LBNL also referred to a

Further, LLNL actually analyzed bioassay samples of LBNL

workers until 1961 (Howe, 1961; Brownk, 1952). In surhmary, NIOSH has insufficient worker

information to associate data reported o1
the LLNL main site or Site 300; the “Li
indicate that the analysis is necessarily aj

NIOSH has obtained tritium results from
The file contained 47,472 tritium results
September 13, 1995 (ORAUT, 2007b).

NIOSH has identified about 1,000 perso:
(LLNL, December 12, 1960-August 31,
results. Almost all of the lapel samples

gross alpha and gross beta results were r
documentation as to what processes wert
potentially exposed workers in that build
sample results represent the exposures 0}

5.2. LLNL External Monitorin

NIOSH has identified personnel externa!

documentation describing LLNL monitoting programs.

regarding the rationale for monitoring (Q
extensive external results, including neu'
available for reconstructing external dos
the geometry and energy ranges experie!
5.3. LLNL Workplace Monitor

LLNL monitored the workplace in an att
has identified air monitoring data dating

NIOSH has access to thousands of result

LBNL data cards with LLNL workers involved in work at
lermore” notations on the LBNL cards do not appear to
sociated with a|LLNL worker.

LLNL in an electronic format suitable for statistical analysis.
with saniple dates ranging from May 3, 1955 through

s . : i
al lapel monitoring records for the periods of 1960 and 1961
961). Each regord contains gross alpha and gross beta

ere taken in Building 125 (Assay Lab). A majority of the
ported as “background.” NIOSH lacks adequate

being conducted, and therefore is unable to determine if all
ling were monitored with the lapel samplers, or if the lapel
the highest exposed individuals in the building.

g Data

monitoring data going back to 1952, as well as

(This documentation includes dialogue
RAUT-TKBS-0035-6, pages 8-11). The data include

Iron exposure data; these external monitoring results are

s. NIOSH has bbtained documentation necessary to define
iced with each process.

fing Data
empt to identify any increasing potential for intakes! NIOSH

back to 1953 for many buildings at LLNL and Site 300.
, mostly total or net alpha and total or net beta results

20 of 33



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

(LLNL, 1961-1962; LLNL, 1960-1961; LLNL, 1960-1962; LRL, 1967). For some results, reported
analytes were listed on the result sheet in terms of element (plutonium, uranium, or thorium), but no
nuclide specific information was provided. NIOSH ‘has also found mixed fission product air
monitoring data linked to seven buildings/areas for the time periods ranging from 1959 through 1967.
The buildings for which fission product monitoring data (gross beta) were found include Buildings
222, 251, 281, 332, 412, 419, and Site 300 (LRL, January 1963-December 1963; LRL, 1966). NIOSH
has air monitoring results for Site 300 for 1964, 1965, 1966; for Building 101 (Chemistry) from 1963
through 1966; and for Building 121 (Biomedical) for 1959 and 1962 through 1967. However, NIOSH
lacks sufficient information to ensure that the results represent the breathing zones of the exposed
workers. NIOSH is therefore unable to use the gross beta results for dose determination in any
specific building.

Included in the air monitoring data are monitoring results for the pool reactor (Building 281) for
portions of each year from 1961 through 1973; however, there are only partial data for some years
(LRL, April 2, 1965-January 3, 1966; LRL, August 30, 1965-November 29, 1965; LLNL, January 14,
1971-January 11, 1973; LRL, 1966; LRL, April 7, 1965-March 9, 1966; LRL, January 7, 1965- April
12, 1965; LRL, August 1964-December 1964; LLNL, January 9, 1969-January 11, 1971; LRL,
November 4, 1963-December 17, 1964; LRL, January 4, 1963-December 30, 1963; LRL, January 3,
1962-January 2, 1963; LLNL, March 1, 1967-January 5, 1968; LRL, February 1, 1962-January 2,
1963; LRL, January 2, 1963-May 6, 1963; LRL, January 1964-August 1964; LRL, May 10, 1963-
December 31, 1963; LRL, January 2, 1968-January 3, 1969). While some assumptions can be
professionally made about the pool reactor operations, NIOSH lacks more specific documentation.on
maintenance activities that could have impacted airborne concentrations during those operations.
Further, NIOSH lacks documentation that indicates how representative the results were of the actual
worker environments.

Although air monitoring data do exist, NIOSH has insufficient information to link specific air
monitoring results to the high-risk work areas. Considering the episodic and dynamic high-activity
work that was associated with laboratory analysis of various nuclear test samples at LLNL, the general
area air sample results available to NIOSH cannot be used to adequately bound the potential air
concentrations that may have existed in the breathing zones of laboratory personnel.

Starting in 1961, LLNL used environmental air monitoring at two site perimeter stations and at nine
stations beyond the site boundary (ORAUT-TKBS-0035-4, page 7). In 1971, LLNL established a
network of permanent outdoor stations to collect air samples to determine airborne radiological levels
both within the site and at its perimeters (Gallegos, 1992). These air samples were analyzed for gross
alpha and beta radiations, tritium, plutonium-239, plutonium-240, uranium-235, and uranium-238
(Gallegos, 1992).

5.4 Radiological Source Term Data

NIOSH has obtained documentation that defines some of the radioactive source term encountered at
LLNL; some data are building specific. Predominant radionuclides in the source term were
plutonium, uranium, and tritium; these are well documented. However, fission and activation
products were also part of the total source term. Fission and activation products were generated as a
result of weapons research, shot sample analysis and handling, development and testing, nuclear fuel

21 of 33



' The Honorable Michael O. Leavitt

|

| January 30, 2008
|

@ NIOSH determined that health may have been endangered for these Mound facility workers.
‘The Board concurs with this determination. |

Enclosed is supporting documentation |from the recent Advisory Board Meeting held in Las Vegas,
Nevada where this class of the special exposure cohort was discussed. If any of these items are

unavailable at this time, they will foll

LOI ne

Paul L. Ziemer, Ph.D.

low shortly.

Sincerely,

Chairman

Enc.



. Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

Lawrence Radiation Laboratory at Livermore. LLNL, which is still in operation under DOE direction,
consists of two sites, the main Laboratory site, which is in a densely populated area in Livermore,
California, and the Explosive Test Site located near Tracy, California (also known as Site 300).

The original mission of LLNL was thermonuclear weapons development. By 1957, and continuing
thereafter, the mission of LLNL was expanded to include diverse scientific and engineering research
activities. These activities have included research, development, testing of the nuclear weapons
lifecycle, strategic defense research, development of arms control and treaty verification technology,
fusion research, atomic vapor laser isotope separation for defense and commercial applications,
magnetic fusion, as well as other energy research in basic energy sciences, atmospheric sciences,
fossil energy, and commercial nuclear waste. Activities were conducted in various buildings at both
LLNL sites (DOE, 1992).

In addition to the research conducted during the development of the site profile and co-worker models,
NIOSH conversed with a former LLNL employee and a current LLNL employee to help understand
the diverse operations at the LLNL site. The former employee was directly involved with operations
involving radioactive materials, as discussed in this report (Bihl, 2007; Chew, 2007). The current
employee is knowledgeable about the database that was supplied to NIOSH (Mansfield, September
2006). Information obtained from these employees has been used in the preparation of the evaluation
report.

LLNL radiological operations included the following operations involving the use of radioactive
materials:

© Strategic defense,

¢ Nuclear propulsion research,

e Inertial confinement fusion research,

¢ Atomic vapor laser isotope separation research,

* Magnetic fusion, including leadership of the U.S. effort on the International Thermonuclear
Experimental Reactor,

© Biological, ecological, atmospheric, and geophysical sciences relevant to weapons, energy, health,
and environmental issues, and

© Charged-particle beam and free-electron laser research for defense and energy applications.

Each of the radiological operations included ancillary functions of chemistry, non-destructive testing,
maintenance, and security (DOE, 1992).

LLNL staff performed a wide array of strategic defense work in the area of nuclear weapon systems.
This work included weapons-systems research and design, and nuclear-weapon-systems

manufacturing and assembly. Initially, LLNL focused their research and development on designing
hydrogen-powered explosives that were smaller in size and yield than weapons developed at the Los

9 of 33


Page 4 - The Secretary

reconstructed using DOE-supplied personal neutron monitoring data and LLNL process
documentation. NIOSH considers reconstruction of external dose possible by using individual
dosimetry records, claimant-favorable assumptions, and the relevant protocols specified in
various complex-wide NIOSH Technical Information Bulletins. NIOSH also considers
reconstruction of medical dose for LLNL workers feasible because medical records are available
for most claimants, as well as claimant-favorable assumptions and protocols to adequately
reconstruct potential LLNL medical dose.

The health endangerment determination is governed by EEOICPA and 42 C.F.R. § 83.13(c)(3)
and § 83.14(b). Pursuant to these requirements, if it is not feasible to estimate with sufficient
accuracy radiation doses for members of the class, then NIOSH must determine that there is a
reasonable likelihood that such radiation doses may have endangered the health of members of
the class. The regulations require NIOSH to assume that any duration of unprotected exposure
may have endangered the health of members of a class when it has been established that the class
may have been exposed to radiation during a discrete incident likely to have involved levels of
exposure similarly high to those occurring during nuclear criticality incidents. If the occurrence
of such an exceptionally high-level exposure has not been established, then NIOSH is required to
specify that health was endangered for those workers who were employed for a number of work
days aggregating at least 250 work days within the parameters established for the class or in
combination with work days within the parameters established for one or more other classes of
employees in the SEC. NIOSH has determined that members of the class were not exposed to
radiation during a discrete incident likely to have involved levels of exposure similarly high to
those occurring during nuclear criticality incidents. However, the evidence NIOSH reviewed
indicates that some workers in the class may have accumulated chronic radiation exposures
through intakes of radionuclides. In summary, NIOSH determined that it is not feasible to
estimate with sufficient accuracy internal radiation doses and that the health of the proposed
class of employees may have been endangered. .

Although NIOSH concluded in its evaluation that there is a lack of sufficient data to permit
estimating and/or reconstructing LLNL internal doses related to mixed fission and activation
products with sufficient accuracy, NIOSH intends to use any available, reliable internal data that
may be included in an individual’s file (and that can be interpreted using existing NIOSH dose
reconstruction processes or procedures) to support a partial internal dose reconstruction for non-
presumptive cancers and/or cases that have less than 250 work days of employment.

After consideration of the NIOSH presentation, the Board voted to advise the Secretary to add
the class. The Board vote was 11-0, with one member recused due to conflict of interest. The
Board letter to the Secretary, received on February 1, 2008, is Tab E. The transcript of the Board
discussion is Tab F.

The petitioner may seek an administrative review of certain HHS decisions, either a class denial
or a 250-workday health endangerment requirement, as specified in the HHS SEC procedures
(42 C.F.R. § 83.18(a), Tab B).

RECOMMENDATIONS



SEC-00092

Lawrence Livermore

12-03-2007 __j National Laboratory (LLNL)

AACG, 1959, Report of Airborne Activii
(AACG); January 7, 1959; SRDB Ref JD:

Anderson, 1964-1965, Logbook of Arth
Arthur L. Anderson; 1964 through 1965

Anderson, 1966, Personal Logbook; A. |

Balanda, 1962, Workplaces for Radionu
October 19, 1961, revised March 28, 19

Balanda, 1966, Personnel Monitoring-R

for Various Facilites; Airborne Activity Control Group
35033

 L. Anderson with Various Dates Between 1964 and 1965;

SRDB Ref ID:|35019 -

. Anderson; 1966; SRDB Ref ID: 14074

ides, Procedure 701-H. C. Manual Part I; John J. Balanda;
2; SRDB Ref IID: 15697

utine Monitoring for Internal Radiation, Procedure 1003-H.

C. Manual Part I; John Balanda; August 25, 1966; SRDB Ref ID: 14029

Bihl, 2006, Recommended Interpretatioi
from Don Bihl; Don E. Bihl; November

Bihl, 2007, Documented Communicatio
2007; SRDB Ref ID: 31425

Browne, 1952, Notes on Gloved Box Ins
correspondence to Al Wilson; Howard B

Chew, 2007, Dose Rate of Shot Test Sam
Rich, Don Morris, and Mike Mahathy;

DOE, 1992, Final Environmental Impac

for Gross: Beta

llation Relative to Architectural Details for Lab Design,

‘Results from LLNL, email correspondence
, 2006; SRDB pefiD: 31381

; communication with Melton Chew; Donald Bihl; April 23,

4

Bl, 1952;  SRDB Ref ID: 21271
ples at LINL, discussion with Mel Chew: Mel Chew, Bryce
jovember 14, 2007; SRDB Ref ID: 36393

‘owne; January

Statement and Environmental Impact Report for Continued

Operation of Lawrence Livermore National Laboratory and Sandia National Laboratories, '

Livermore, DOE/EIS-0157; U.S. Departr

DOE, 2000, United States Nuclear Tests+
Department of Energy (DOE); December

nent of Energy WOE); August 1992; SRDB Ref ID: 24749

July 1945 thrdugh September 1992, DOE/NV--209- Rev 15;

2000; SRDB Ref ID: 2433

Gallegos, 1992, Environmental Monitoring Plan; Gretchen M. Gallegos, Kris A. Surano, Kenneth (on

Lamson, Paula J. Tate, Brian K. Balke, Al

Frank J. Gouveia, Robert L. Berger, Fred|
1992; SRDB Ref ID: 23047

Gallegos, 2001, LLNL NESHAPs 2000 A
Robert J. Harrach, Robert L. Berger, Nic!
June 200]; SRDB Ref ID: 23049

Grill, 1965, Bioassay List, memo to Dr.
1965; SRDB Ref ID: 20781

Irthur H. Biermann, William G. Hoppes, Barbara C. Fields,

S. Miller, Duane W. Rueppel, and John M. Sims; April

nual Report, UCRL-ID-113867-01; Gretchen M. Gallegos,
olas A. Bertoldo, Paula J. Tate, and Sylvie-Ring Peterson;

. R. Powell and Dr. L. R. Scheer; R. P. Grill; December 29,

28 of 33



SEC-00092

12-03-2007

Lawrence Livermore
National Laboratory (LLNL)

Thi

page intentiona

Ily blank

26 of 33



occupational medical dose and the external dose. Therefore, individuals with
non-presumptive cancers may be considered for partial dose reconstructions.

Health Endangerment

The Secretary established the health endangerment determination for the class of
employees covered by this report based upon the findings summarized below.

(1) Pursuant to 42 C.F.R. § 83.13(c)(3), NIOSH established that there is a reasonable
likelihood that such radiation doses may have endangered the health of members
of the class. Pursuant to 42 C.F.R. § 83.13(c)(3)(ii), NIOSH specified a minimum
duration of employment to satisfy this health endangerment criterion as “having
been employed for a number of work days aggregating at least 250 work days
within the parameters established for this class or in combination with work days
within the parameters (excluding aggregate work day requirements) established
for one or more other classes of employees in the Cohort.”

(2) NIOSH did not identify any evidence from the petitioners or from other resources
that would establish that the class was exposed to radiation during a discrete
incident likely to have involved exceptionally high-level exposures, such as a
nuclear criticality incident, as defined under 42 C.F.R. § 83.13(c)(3)(i).

(3) The Board concurred with NIOSH’s finding that the health of the class may have
been endangered and defined the class according to the 250-workday requirement
specified under 42 C.F.R. § 83.13(c)(3)(ii).

V. Effect and Effective Date of Designation

The Secretary submits this report on the designation of one additional class to the
SEC for review by Congress, pursuant to 42 U.S.C. §§ 7384/(14)(C)(ii) and
7384q(c)(2)(A), as amended by the Ronald W. Reagan National Defense
Authorization Act for Fiscal Year 2005, Pub. L. No. 108-375 (codified as amended in
scattered sections of 42 U.S.C.). Pursuant to 42 U.S.C. § 7384/(14)(C)(ii), as
amended by the Ronald W. Reagan National Defense Authorization Act for Fiscal
Year 2005, Pub. L. No. 108-375 (codified as amended in scattered sections of 42
U.S.C.), the designation in this report will become effective 30 days after the date of
this report’s submission to Congress “unless Congress otherwise provides.”

VI. Administrative Review of Designation

The health endangerment determination of the designation provided in this report
may be subject to an administrative review within HHS, pursuant to 42 C.F.R. §
83.18(a). On the basis of such a review, if the Secretary decides to expand the class
of employees covered by this designation, the Secretary would transmit a
supplementary report to Congress providing the expanded employee class definition
and the criteria and findings on which the decision was based.

HHS Special Exposure Cohort Designation:
Lawrence Livermore National Laboratory



Tab C

SEC Petition



Page 3 — The Secretary

sample results available to NIOSH cannot be used to adequately bound the potential air
concentrations that may have existed in the breathing zones of LLNL staff.

Further, while some of the fission and activation product source term information is known,
NIOSH does not have information to sufficiently quantify the activity levels for the wide array of
fission product radionuclides encountered throughout the LLNL site.

Although the pre-1974 air monitoring and source term information available to NIOSH is not
adequate for sufficiently accurate dose reconstruction, these data do show that fission product
radionuclides either were used or exposure to them was'expected in a wide array of buildings
throughout the site. Therefore, because there was a lack of sufficient bioassay, air monitoring,
and source term data, NIOSH finds that it is not feasible to reconstruct, with sufficient accuracy,
the internal doses from intakes of fission and activation products potentially received at LLNL
during the period from January 1, 1950, through December 31, 1973.

Some limited documentation may be available to match radiological workers to specific
locations; however, many of these workers were likely assigned to multiple locations, and as
such, the proposed class cannot be restricted to a. specific job title or occupation. Further,
NIOSH does not have workplace monitoring documentation to demonstrate that fission and
activation products were not used or stored in other areas of LLNL involved in radiological
activities. NIOSH does not have information to definitively limit the generation, use, processing,
or spread of fission product radionuclides to specific LLNL locations within the buildings where
radioactive material was handled or stored; thus, the NIOSH proposed class definition includes
all known LLNL locations that handled or stored radioactive material. However, NIOSH has no
indication that exposures to mixed fission products and activation products would have been a
concer in administrative areas outside of radiological areas (e.g., cafeterias, libraries, and office
areas outside of radiological areas).

The above also explains why the class definition refers only to workers "who were monitored,”
rather than the usual class definition language of "who were monitored or should have been
monitored." The Department of Labor (DOL) requested that individual buildings be listed, but
because NIOSH does not have the information needed to specify which buildings on the site
contained radiological material that could have led to such internal doses, but does have
documentation indicating that everyone who entered buildings where there was a potential for
radiological exposure was badged, NIOSH used the seemingly more-limiting language to define
the proposed class more accurately. Had NIOSH, for instance, listed specific LLNL buildings in
the class definition as being included or excluded, any subsequent change in building status
would have required a Secretarial action to revise the class. Similarly, the language in the class
definition has been changed from "for internal exposure to mixed fission and/or activation
product radionuclides" to "radiation exposure" for accuracy and ease of application to
compensation decisions by DOL.

For external dose, beta and photon doses received from exposure to uranium, plutonium, fission
products, and other sources can be reconstructed for LLNL workers for the entire covered period
using available monitoring data that were provided by DOE and obtained by NIOSH during on-
site data captures for LLNL. NIOSH also considers the reconstruction of neutron doses to be
possible for workers who were potentially exposed to neutrons. Neutron doses can be



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

and testing of the whole body counter was in a state of evolution at the time, and NIOSH lacks the
information necessary to validate the calibration and radionuclide efficiencies associated with the zinc
in vivo analyses.

With the exception of the 325 gross beta results reported by LLNL, NIOSH does not have in vitro
bioassay results for exposures to mixed fission products through 1973. NIOSH reviewed mixed
fission product in vitro results recorded by LLNL through 1980. As presented in Table 5-1, the
number of mixed fission product analyses increased in 1974, peaking in 1978.

ee e ers + Table 5:1:-Mixed Fission:ProductIn Vitro Bioassay Analyses
Year | # of Individuals # of Results # of Known Locations Location(s)
1972 2 2 2 Radiochemistry, Waste Disposal
1973 16 16 4e Biomedical, Hazards Control, Pool

Reactor, Radiochemistry
Assay Lab, Biomedical, Chemistry,

7 Diagnostic Chemistry, Metallurgical
1974 35 42 ° Chemistry, Pool Reactor, Safeguards and
Engineering, Waste Disposal
Assay Lab, Assembly and Test, Biomedical,
Chemistry, Classified Storage, Hazardous

Wastes, Hazards Control, Lab Services,

1975 39 79 1a* Mechanical Engineering, Pool Reactor,
Safeguards and Engineering, R&D,
Radiochemistry, Waste Disposal
Assay Lab, Assembly and Test, Biomedical,
Chemistry, Classified Storage, Hazards
Control, Lab Services, Mechanical
Engineering, Pool Reactor, R&D,
Radiochemistry, Safeguards and
Engineering, Waste Disposal, 1575, 2506
Assay Lab, Biomedical, Diagnostic
Chemistry, Dry Waste, Metallurgical
Chemistry, Pool Reactor, R&D,
Radiochemistry, Storage, Waste Disposal
Assay Lab, Diagnostic Chemistry, Dry
Waste, Engineering, Hazards Control,
Heavy Element Facility, Metallurgical
Chemistry, Pool Reactor, Radiochemistry,
Refractory Materials, Site 300, Storage,
Waste Disposal
Accelerators, Assay Lab, Dry Waste,
1979 40 73 7 Metallurgical Chemistry, Pool Reactor,
Radiochemistry, Waste Disposal
Assay Lab, Biomedical, Dry Waste,
1980 26 30 7* Hazards Control, Pool Reactor,
Radiochemistry, Waste Disposal

1976 34 70 13*

1977 45 96 10*

1978 68 100 13*

Note:
* indicates that the location could not be determined for some worker bioassay results

19 of 33



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

SEC Petition Evaluation Report for SEC-00092

1.0 Purpose and Scope

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from
the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: James
Mahathy, Oak Ridge Associated Universities. These conclusions were peer-reviewed by the
individuals listed on the cover page. The rationales for all conclusions in this document are explained
in the associated text.

This report evaluates the feasibility of reconstructing doses for employees who worked at specific
facilities during a specified time. It provides information and analysis germane to considering a
petition for adding a class of employees to the Congressionally-created Special Exposure Cohort
(SEC).

This report does not make any determinations concerning the feasibility of dose reconstruction that
necessarily apply to any individual energy employee who might require a dose reconstruction from
NIOSH, with the exception of the employee whose dose reconstruction could not be completed, and
whose claim consequently led to this petition evaluation. The finding in this report is not the final
determination as to whether or not the proposed class will be added to the SEC. This report will be
considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary
of Health and Human Services (HHS). ‘The Secretary of HHS will make final decisions concerning
whether or not to add one or more classes to the SEC in response to the petition addressed by this
report.

This evaluation, in which NIOSH provides its findings on both the feasibility of estimating radiation
doses of members of this class with sufficient accuracy and on health endangerment, was conducted in
accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14.

2.0 Introduction

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting the
Department of Health and Human Services to add a class of employees to the SEC. The evaluation is
intended to provide a fair, science-based determination of whether it is feasible to estimate, with
sufficient accuracy, the radiation doses of the proposed class of employees through NIOSH dose
reconstructions.'

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose
reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated
Universities (ORAU). Once completed, NIOSH provides the report to both the petitioners and to the
Advisory Board on Radiation and Worker Health. The Board will consider the NIOSH evaluation

' NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and
the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas.

7 of 33



Page 2 — The Secretary

HHS report to Congress on both decisions to add and decisions to deny a designation within 30
days of HHS receiving a recommendation by the Advisory Board on Radiation and Worker
Health (Board) to add the class to the SEC. Failure to report to Congress within this 30-day
deadline would result in the automatic addition of the class to the SEC.

42 CFR. § 83.14 permits an SEC petition initiated by National Institute for Occupational Safety
and Health (NIOSH) when it has attempted to conduct a dose reconstruction for a cancer
claimant and finds that the dose reconstruction cannot be completed because there is insufficient
information to estimate the radiation doses of the claimant with sufficient accuracy. NIOSH
reached this conclusion for a LLNL claimant and subsequently both notified the claimant and
provided information to the claimant about the SEC petitioning process. NIOSH assisted the
claimant in completing the SEC petition for qualification (Tab C). NIOSH evaluated the petition
and presented the findings (Tab D) at the Board meeting in Las Vegas, Nevada, on January 8,
2008. The NIOSH evaluation recommended adding the following proposed class to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and DOE
contractors or subcontractors who were monitored for radiation exposure while working
at the Lawrence Livermore National Laboratory from January 1, 1950, through
December 31, 1973, for a number of work days aggregating at least 250 work days or in
combination with work days within the parameters established for one or more other
classes of employees in the Special Exposure Cohort.

NIOSH has located thousands of bioassay monitoring results for LLNL employees. In addition
to the MAPPER (Maintaining and Preparing Executive Reports, a data storage system developed
for LLNL by the Sperry Corporation) data supplied by LLNL, NIOSH has access to individual
bioassay results reported for 617 claimants using data stored in the NIOSH OCAS Claims
Tracking System (NOCTS). However, records for less than 5% of the claims contain bioassay
results for mixed fission products.

Using the MAPPER bioassay data, NIOSH has developed coworker intakes for both uranium
(starting in 1958) and mixed fission products (starting in 1974). These derived coworker intakes
can be used to reconstruct doses for those radionuclides and time periods for all LLNL workers
and all LLNL locations. NIOSH has access to only limited fission product bioassay data for the
period prior to 1974, consisting of data available in NOCTS for less than 30 claimants, 325 gross
beta results from MAPPER, and zinc-65 in vivo data for 1965 and 1966 for 16 cyclotron
workers. NIOSH has been unable to obtain additional in vivo counting results adequate for dose
reconstruction for the period prior to 1974. The in vivo logbooks examined by NIOSH further
indicate that LLNL staff members were routinely modifying the design of the in vivo facility
during this timeframe. NIOSH finds these limited pre-1974 bioassay data insufficient to develop
sufficiently accurate co-worker fission product intake models.

While NIOSH has access to some fixed and personal airborne monitoring data that indicate the
presence of fission and activation product radionuclides, those data cannot be used to bound or
reconstruct doses with sufficient accuracy. Breathing zone results are available for only one
building and only for portions of 1960 and 1961. Considering the high-activity work that was
associated with laboratory analysis of various nuclear test samples at LLNL, and the unknown
characteristics of biomedical, research, and waste management activities, the general area air



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

LLNL, 1980-1981, Whole-Body Counter #2 Logbook #12, January 14, 1980 to February 3, 1981;
Lawrence Livermore National Laboratory (LLNL); January 14, 1980 through February 3, 1981;
SRDB Ref ID: 35031

LLNL, 1985, Health and Safety Discipline Program-Site 300, discipline action plan; Lawrence
Livermore National Laboratory (LLNL); 1985; SRDB Ref ID: 16007

LLNL, 2005, LLNL Building Index: Pre 1966 and Post 1966, facsimile to J.J. Maisler (Integrated
Environmental Management, Inc.), Livermore, California; February 15, 2005; SRDB Ref ID: 16948

LLNL, 2006, Lawrence Livermore Timeline; Lawrence Livermore National Laboratory (LLNL); May
2, 2006; located at http://www.|InI.gov/timeline

LLNL & LBNL, 1960-1968, Bioassay Cards; Lawrence Livermore National Laboratory (LLNL) and
Lawrence Berkley National Laboratory (LBNL); 1960 through 1968; SRDB Ref ID: 32379

LLNL & LBNL, January 1960-August 1962, Bioassay Cards, cards #1-407; Lawrence Livermore
National Laboratory (LLNL) and Lawrence Berkley National Laboratory (LBNL); January 1960
through August 1962; SRDB Ref ID: 32378

LRL, January 3, 1962-January 2, 1963, Hazards Control Radioactivity Sampling Records, Air
Monitoring for Building 193; January 3, 1962 through January 2, 1963; SRDB Ref ID: 36055

LRL, February 1, 1962-January 2, 1963, Hazards Control Radioactivity Sampling Records, Air
Monitoring for Building 193; February 1, 1962 through January 2, 1963; SRDB Ref ID: 36192

LRL, January 1963-December 1963, Hazards Control Radioactivity Sampling Records, Building 125
air sample cards; Lawrence Radiation Laboratory (LRL); January 2, 1963 through December 31,
1963; SRDB Ref ID: 35141

LRL, January 1963-January 1964, Computation of Radioactivity Results, Building 121 Air
monitoring; Lawrence Radiation Laboratory (LRL); January 1963 through January 1964; SRDB Ref
ID: 36068

LRL, January 2, 1963-May 6, 1963, Hazards Control Radioactivity Sampling Records, Air
Monitoring for Building 193; January 2, 1963 through May 6, 1963; SRDB Ref ID: 36198

LRL, January 4, 1963-December 30, 1963; Computation of Radioactivity Results, Building 193;
January 4, 1963 through December 30, 1963; SRDB Ref 1D: 36051

LRL, May 10, 1963-December 31, 1963, Hazards Control Radioactivity Sampling Records, Air

Monitoring for Building 193; Lawrence Radiation Laboratory (LRL); May 10, 1963 through
December 31, 1963; SRDB Ref ID: 36230

31 of 33



Lawrence Livermore
SEC-00092 12-03-2007 National Laboratory (LLNL)

monitor a particular project (Bihl, 2007). Different labs in a common building were sometimes
associated with unique source terms, including fission products (Bihl, 2007).

While no specific operations or buildings were identified, Internal Ionizing Radiation Exposure
Standards, Procedure 202 listed maximum permissible concentrations in air for cobalt-60, cesium-
137, and strontium-90 (Unknown author, 1961). Another LLNL document further lists twenty-nine
buildings as approved for handling fission products and other radionuclides (Balanda, 1962). An
examination of bioassay data for the period from 1972 through 1980 showed that employees in thirty-
six LLNL buildings/locations were monitored for exposures to mixed fission products (ORAUT,
2007a). NIOSH has also found mixed fission product air monitoring data for seven of those thirty-six
buildings from 1959 through 1967, further indicating site concern for fission product exposures. The
buildings for which fission product bioassay and/or monitoring data were found include Buildings
222, 251, 281, 332, 412, 419, and Site 300 (LLNL, 1965-1967; LLNL, 1960-1970; LRL, August
1964-December 1964; LRL, January 1963-January 1964; LRL, January 1964-October 1964; LRL,
January 1965-December 1965).

NIOSH research indicates that fission and activation products were either used or generated in the
buildings listed in Table 4-2.

Table 4-2: Buildings Involved with Fission and Activation Products
Current Building Number Operations/Activities
101, 125, 132, 151, 162, 165, 166, 167, 168, 169, Chemistry, nuclear and radiochemical analyses/tests, lab
171, 173, 174, 175, 176, 182, 217, 221, 222, 223, services, and. radiological calibrations, isotope sciences, tracer
224, 243, 253, 254, 255, 334 and dissolution studies , research
192, 194, 210, 212, 241, 298. 327, 341. 421, 435, Accelerators-studies
281 Reactor
361, 362, 363, 364, 365, 366, 377, 378, 412 Biomedical studies
241, 412, 513, 514, 612, 614 Yard, 625 Waste operations
Site 300 (All buildings and areas) Linear accelerators, radiography, Plowshare programs

Sources: ORAUT, 2007a; LLNL, 2005; LLNL, 1965-1967; AACG, 1959; ORAUT-TKBS-0035-2, pages 9-19

A list of fission and activation products encountered in these buildings is listed in ORAUT-TKBS-
0035-2, pages 11-13. While NIOSH has access to documents that describe some of the activities and
radionuclides specific to certain buildings, NIOSH does not have sufficient data to document the
quantities and types of most fission products and activation products. NIOSH also does not have
sufficient information to rule out the use of fission and activation products in other buildings where
radioactive material was handled and stored. However, NIOSH has no indication that exposures to
mixed fission products and activation products would have been a concern in administrative areas
outside of radiological areas (e.g., cafeterias, libraries, and office areas outside of radiological areas)

4.3 Time Period Associated with Radiological Operations

Mixed fission products and/or activation products were potentially produced, generated, used, handled,
and/or stored with all operations and tasks conducted at LLNL from January 1, 1950 through
December 31, 1973. Several LLNL operations produced, generated, used, handled, and/or stored
mixed fission products and/or activation products beyond December 31, 1973 and continue to do so
today. However, NIOSH has the in vitro and in vivo bioassay monitoring data needed to reconstruct

15 of 33



SEC-00092

Lawrence ‘Livermore

12-03-2007 National Laboratory (LLNL)

Beta and photon doses received from ex]
sources can be reconstructed for LLNL

monitoring data that were provided by D
LLNL. NIOSH also considers the recon}
were potentially exposed to neutrons. N

osure to uranium, plutonium, fission products, and ‘other
orkers for the entire covered period using available
OE and obtained by NIOSH during on-site data captures for
doses to be possible for workers who

struction of neutron
utron doses can be reconstructed using DOE-supplied

personal neutron monitoring data and|LILNL process documentation (the latter is presented in

ORAUT-TKBS-0035-6, pages 8-11).'

OSH considers| reconstruction of external dose possible by

using individual dosimetry records, claitnant-favorable assumptions, and the relevant protocols

specified in various complex-wide.Techhical Information Bulletins.

NIOSH considers reconstruction of medical dose for LL!

are available for most claimants. NIOS!
specified in ORAUT-OTIB-0006 to ade

’

7.0 Summary of Feasibility Findings for Petition SEC-00092

This report evaluates the’ feasibility for dstimating dose,

NL workers feasible because medical records
laimant-favorable assumptions and protocols
ict potential LLNL medical dose. *

can also use c

uately reconstri
i

ith sufficient accuracy, for all employees of

the DOE, its predecessor agencies, and IDOE contractors of subcontractors: who were monitored, or

should have been monitored, for exposu
while working at the Lawrence Liverm

aggregating. at least 250 Work days from
determined that it lacks sufficient fission
monitoring data to adequately reconstru
to fission and activation products receiv
NIOSH finds that it is not feasible to est}
received by members of this class of em]

NIOSH has documented herein that it cq
for doses resulting from exposure to mi.
finding, specified in this report, demons}
information to estimate, with sufficient
member of the class or to estimate such
estimate. Members. of this class may ha)
mixed fission product radionuclides res
information, which includes sufficient p
source term information, to allow it to e:
proposed class may have been exposed.

8.0 Evaluation of Health E

eto mixed fission and/or activation product radionuclides
e National Laboratory. for a number of work days '
Jdnuaty 1, 1950 through December 31, 1973. NIOSH
product bioassay, source term data, and workplace

t radiation doses resulting from potential internal exposures
d by members Of this class of employees. Consequently,
imate, with sufficient accuracy, the total radiation dose

ployees.

innot complete the dose reconstructions related to this petition
led fission and/or activation products. The basis of this

rates that NIOSH does not have access to sufficient

ccuracy, either he maximum radiation dose incurred by any
adiation doses more precisely than a maximum dose

e received unmlonitored internal radiological exposures from
Iting from work conducted at LLNL. NIOSH lacks sufficient
ersonnel and workplace monitoring data and radiological

timate the potential total internal exposures to which the ©

ndangerment for Petition SEC-00092

24 of 33



SEC-00092

i
|

Lawrence Livermore

12-03-2007 National Laboratory (LLNL)

Alamos National Laboratory. The first
megaton-class warhead used for the Pol:
Minuteman missile, as well as the W48
1973, LLNL developed the W70 warhea‘
1976, LLNL was asked to modify the Lal
capability (LLNL, 2006). Weapons asse
491, 512, and other buildings over time (|

Planning and conducting weapons tests

mission. Starting in 1953, LLNL conduq
both the Pacific Proving Ground and at t
offsite, test planning and preparation wei
explored a new design for fission device:
provided information about certain therm
performed eleven nuclear tests during 19]
LLNL staff, was performed in 1954 at thy
KOON, conducted during 1954, had a pr
kiloton (LLNL, 2006). In September 19
first contained underground nuclear exp!
nuclear testing moratorium, LLNL condu
studies using depleted uranium, thorium,
Williams, 1977; LLNL, 2006); however,
1969, only natural uranium, depleted urai

: explosives (LRL, January 3, 1969-December 31, 1969).

In 1962, the United States resumed nucle
Operation Dominic, the largest nuclear tq

LLNL managed the CANNIKIN test eve:

undertaking that involved hundreds of LI]

date; DOE, 1992). The total number of t
Table 4-1 (DOE, 2000).

is missile. In the 1960s, LLNL developed warheads for the

ms ma design that resulted from this research was a

arhead for use with 155-millimeter howitzer artillery. In
dl that was deployed on the short-range Lance missile. In
hce W-70 warhéad by adding an enhanced radiation
mbly activities were conducted in Buildings 102, 432, 435,
Harrach, 2003).}

|
ere critical work components of the strategic defense
ted above-ground (atmospheric) and underground tests at
ie Nevada Test Site (NTS). Although tests were conducted
fe done at LLNL. The first nuclear test conducted by LLNL
that offered hope for smaller, more efficient bombs and
lonuclear reactidns; however, that test failed. LLNL
63, all at NTS. The first thermonuclear test, conducted by
b Pacific Proving Ground (DOE, 2000). Another test,
edicted yield of 1 megaton but the actual yield was only 110
7, in a tunnel at the Nevada Test Site, LLNL detonated the
sion (DOE, 2000). Beginning in 1959, in the midst of a
cted mock testing of nuclear designs and hydrodynamic
land other radioactive materials at Site 300 (LLNL, 1985;
ltests conductediat Site 300 did not use fissile materials. By
ium, and natural thorium were allowed for testing with high

ar weapons testing using fissile materials; LLNL staff co-led
st ever conducted at the Pacific Proving Ground. In 1971,

nt at Amchitka Island, Alaska. That operation was a massive
NL employees and nearly five years of effort (LLNL, no

sts sanctioned by LLNL is shown by year and by type in

Table 4-1: LLNL Sanctioned Tests A
This table spans two\pages. a
Year Number of Underground Test | Number of Atmospheric Tests
1953 - | 3
1954 - f 1
1955 : t 3
1956 : 8
[ 1957 1 I 12
1958 7 | 27
1961 4 | :
1962 33 | 20
1963 23 | :
1964 30 | :
1965 22 | 1 é
1966 25 | : >
1967 23 I -
|

10 of 33

i
|



I. Designation

I, Michael O. Leavitt, Secretary of Health and Human Services (Secretary), designate
the class of employees defined in Section II of this report for addition to the Special
Exposure Cohort (SEC), as authorized under the Energy Employees Occupational
Illness Compensation Program Act of 2000 (EEQJCPA), 42 U.S.C. § 7384q.

MAR - 3 2008
t

Date Michael O. Leavitt

Il. | Employee Class Definition

Employees of the Department of Energy (DOE), its predecessor agencies,
and DOE contractors or subcontractors who were monitored for radiation
exposure while working at the Lawrence Livermore National Laboratory
from January 1, 1950, through December 31, 1973, for a number of work
days aggregating at least 250 work days or in combination with work days
within the parameters established for one or more other classes of
employees in the Special Exposure Cohort.

III. Designation Criteria and Recommendations

Pursuant to 42 U.S.C. § 7384q, for the class defined in Section II of this report, the
Secretary has determined, and the Advisory Board on Radiation and Worker Health
(Board) has recommended, that
(1) it is not feasible to estimate with sufficient accuracy the radiation dose that the
class received; and
(2) there is a reasonable likelihood that such radiation dose may have endangered
the health of members of the class.

The SEC final rule states in 42 C.F.R. § 83.13(c)(1) that it is feasible in two situations
to estimate the radiation dose that the class received with sufficient accuracy. First,
the rule states that radiation doses may be estimated with sufficient accuracy if
NIOSH has established that it has access to sufficient information to estimate the
maximum radiation dose for every type of cancer for which radiation doses are
reconstructed that could have been incurred under plausible circumstances by any
member of the class. Alternatively, radiation doses may be estimated with sufficient
accuracy if NIOSH has established that it has access to sufficient information to
estimate the radiation doses of members of the class more precisely than a maximum
dose estimate.

HHS Special Exposure Cohort Designation:
Lawrence Livermore National Laboratory



SEC-00092

Lawrence Livermore
National Laboratory (LLNL)

|

12-03-2007

LRL, November 4, 1963-December 17,
Lawrence Radiation Laboratory (LRL);
ID: 36048

LRL, 1964-1967, Hazards Control Radi
Laboratory (LRL); 1964 through 1967;

LRL, January 1964-August 1964, Haza
Lawrence Radiation Laboratory (LRL);

LRL, January 1964-October 1964, Haza|
Lawrence Radiation Laboratory (LRL);

LRL, August 1964-December 1964, Haz
Lawrence Radiation Laboratory (LRL);

LRL, 1965, Hazards Control Radioacti
Laboratory (LRL); May 1965 through N

LRL, January 1965-December 1965, Ha:
. Lawrence Radiation Laboratory (LRL);

“LRL, January 7, 1965- April 12, 1965, 4
. 193; Lawrence Radiation Laboratory (L
35152

LRL, April 2, 1965-January 3, 1966, Ha
. Lawrence Radiation Laboratory (LRL);

LRL, April 7, 1965-March 9, 1966, Haz.
Lawrence Radiation Laboratory (LRL);

LRL, August 30, 1965-November 29, 19

Building 900; Lawrence Radiation Labor
SRDB Ref ID: 35126

LRL, 1966, Hazards Control Radioactivi
Laboratory (LRL); March 1966 through

LRL, 1967, Hazards Control Radioactivi
Laboratory (LRL); January 1967 through

LRL, January 2, 1968-January 3, 1969, H
281; Lawrence Radiation Laboratory (LR
36240

964, Computation of Radioactivity Results, Building 193;
jovember 4, 1963 through December 17, 1964; SRDB Ref

1

activity Sampling Records, 300 Area; Lawrence Radiation
RDB Ref ID: 35090

ds Control Radioactivity Sampling Records, Building 193;
January 1964 through August 1964; SRDB Ref ID: 36225

yds Control Radioactivity Sampling Records, Building 101;
January 1964 tjowsh October 1964; SRDB Ref ID: 36071
ards Control Radioactivity Sampling Records, Building 193; .
August 1964 through December 1964; SRDB Ref ID: 35156

ity Sampling Records, Building.400; Lawrence Radiation
bvember 1965; SRDB Ref ID: 35127 i
zards Control Radioactivity Sampling Records, Building 125;
lanuary 1965 thtough December 1965; SRDB Ref 1D: 36227
fazards Control\Radioactivity Sampling Records, Building

RL); January 7, {96s through April 12,1965; SRDB Ref ID:

i
ards Control Radioactivity Sampling Records, Building 193;
April 2, 1965 through January 3, 1966; SRDB Ref ID: 35125

rds Control Radioactivity Sampling Records, Building 193;
April 7, 1965 through March 9, 1966; SRDB Ref ID: 35149

65, Hazards Control Radioactivity Sampling Records,
ratory (LRL); August 30, 1965 through November 29, 1965;

ity Sampling Records, Building 193; Lawrence Radiation

ovember 1966: SRDB Ref ID: 35140

ity Sampling Records, Building 171; Lawrence Radiation
February 1967, SRDB Ref ID: 35123

fazards Control Radioactivity Sampling Records, Building
L); January 2, 1968 through January 3, 1969; SRDB Ref ID:

\
32 of 33 : |

|



Tab E

Board Recommendation Letter to Secretary Leavitt



Tab B

42 CFR. pt. 83